DOCKET NO: A-98-49, II-A4-104

WASTE CHARACTERIZATION INSPECTION REPORT

FINAL APPROVAL

EPA BASELINE INSPECTION NO. EPA-SRS-CCP-RH-07.07-8 OF THE CENTRAL CHARACTERIZATION PROJECT REMOTE-HANDLED TRANSURANIC WASTE CHARACTERIZATION PROGRAM FOR BATTELLE COLUMBUS LABORATORIES DECOMMIS SIONING

PROJECT WASTES STORED AT THE SAVANNAH RIVER SITE

July - December, 2007

U.S. Environmental Protection Agency Office of Radiation and Indoor Air Center for Waste Management and Regulations 1200 Pennsylvania Avenue, NW Washington, DC 20460

August 2008**i** TABLE OF CONTENTS

**Section Page** 

**Acronyms ...........................................**

**................................................... .........................................iii**  **1.0 Executive Summary ..............................**

**................................................... ........................... 1**  **2.0 Purpose of Inspection..........................**

**................................................... ............................. 3**  **3.0 Purpose of this Report.........................**

**................................................... ............................. 4**  **4.0 Scope of Inspection ............................**

**................................................... .............................. 5**  **5.0 Inspection-Related Definitions.................**

**................................................... ........................ 6** 

**6.0 Personnel ......................................**

**................................................... .................................... 6**  **6.1 EPA Inspection Team............................**

**................................................... ............... 6** 
**6.2 Personnel Contacted............................**

**................................................... ................. 7**  **7.0 Performance of the Inspection..................**

**................................................... ........................ 7** 

**8.0 Technical Evaluation...........................**

**................................................... ............................. 8**  **8.1 Acceptable Knowledge Process Overview and Analy sis...................................... 20**  **8.2 Radiological Characterization..................**

**................................................... .......... 32**  **8.3 Physical Form and Prohibited Item Characterizat ion – Visual Examination........ 46**  **8.4 WIPP Waste Information System ..................**

**................................................... .... 48**  **8.5 Attainment of Data Quality Objectives..........**

**................................................... .... 49**  **9.0 Response to Comments ...........................**

**................................................... ....................... 50** 

**10.0 Conclusions ...................................**

**................................................... ................................. 52**  **Baseline Approval..................................**

**................................................... ........................ 52** 

**11.0 References ....................................**

**................................................... .................................. 53** 

ATTACHMENTS

**Attachment A EPA Inspection Issue Tracking Form,**

**EPA Issue No. SRS-CCP-RH-AK-07-001F ................. .................................. 61** **ii** LIST OF TABLES

**Table 1. EPA Inspection Team Members ..............**

**................................................... ..................... 6**  **Table 2. Personnel Contacted during Inspection....**

**................................................... ..................... 7**  **Table 3. Details of EPA Finding No. SRS-RH-K-07-00 1F .................................................**  **........ 22 Table 4. Summary of the Reported Radionuclides in**  **the 69 Smear Samples.............................. 3 4**  **Table 5. Radionuclide Scaling Factors.............**

**................................................... ......................... 39**  **Table 6. Overall Uncertainty Listed by Radionuclid e at a Density of 1.0 g/cm**  **3 ......................... 44** 

LIST OF FIGURES

**Figure 1. Configuration and Dimensions of a 55-Gal lon Drum TRU RH Liner ......................... 10**  **Figure 2. Comparison of Scaling Factors Representa tive of Different Fuel Types Against** 

**Average Smear Sample Scaling Factors...............**

**................................................... ..... 36**  **Figure 3. DTC Correlations as a Function of Waste Density at a Distance of 1 meter** 

**Centered on a RH TRU Drum Liner ....................**

**................................................... ..... 40**  **Figure 4. Example Waste Drum DTC Conversion Record**

**................................................... ....... 41** **iii** ACRONYMS

**AK acceptable knowledge AKE acceptable knowledge expert** 

**Am americium ANLE Argonne National Laboratory-East** 

**ANSI American National Standards Institute**

**Ba barium**

**BC Battelle Columbus BCL Battelle Columbus Laboratory**  **BCLDP Battelle Columbus Laboratory Decommissioning Project**  **BDR batch data report**

**BMI Battelle Memorial Institute CAR Corrective Action Report** 

**CBFO Carlsbad Area Field Office CCP Central Characterization Project** 

**CFR** Code of Federal Regulations

**CH contact-handled**

**CH-TRAMPAC Contact-Handled Transuranic Waste Author ized Methods for Payload Control** 

**Ci curie Ci/Ci curies per curie**  **Ci/L curies per liter**

**Cm curium**

**Co cobalt CPR cellulose, plastic, and rubber**  **CRR Characterization Reconciliation Report**

**Cs cesium**

**CTAC Carlsbad Technical Assistance Contractor CTP Confirmatory Test Plan**  **D&D decontamination and decommissioning DOE U.S. Department of Energy**  **DQO data quality objective DR discrepancy resolution** **iv**

**DTC dose-to-curie EPA U.S. Environmental Protection Agency**  **FGE fissile gram equivalent**

**FR** Federal Register **Eu europium**

**g gram g/cm**  **3 grams per cubic centimeter**  **HCL Hot Cell Laboratory HEU highly enriched uranium**  **HLW high-level waste INL Idaho National Laboratory**  **kg kilogram LANL Los Alamos National Laboratory** 

**LLD lower limit of detection**

**LWA** Land Withdrawal Act **LWR light-water reactor**

**m 3**  **cubic meter MDA minimum detectable activity**  **mR/hr milli Roentgen per hour mrem/hr millirem per hour**  **MSDS material safety data sheets N/A not applicable**  **nCi/g nanocurie per gram NCR non-conformance report** 

**NDE non-destructive examination Np neptunium** 

**ORIA Office of Radiation and Indoor Air PE Ci plutonium equivalent curie**  **PTS Project Tracking System Pu plutonium**  **QA quality assurance QAO quality assurance objective**  **QAPD quality assurance program description v** 

**R/hr/Ci Roentgen per hour per curie RCRA Resource Conservation and Recovery Act** 

**RH remote-handled RIDS Record Inventory and Disposition System**  **RTR real-time radiography Sb antimony**  **SCG Summary Category Group SNF spent nuclear fuel**  **SPM Site Project Manager**

**Sr strontium**

**SRS Savannah River Site**

**Th thorium**

**T1 Tier 1**

**T2 Tier 2**

**TBD to be determined TMU total measurement uncertainty** 

**TRU transuranic**

**U uranium**

**VE visual examination VEE visual examination expert**  **WAC waste acceptance criteria**

**WC waste characterization**

**WCO Waste Certification Official WCPIP Waste Characterization Program Implementation**  **Program**

**WIPP Waste Isolation Pilot Plant**

**WMC waste matrix code WMP waste material parameter** 

**WSPF Waste Stream Profile Form WWIS WIPP Waste Information System**  **Y yttrium 1** 

1.0 EXECUTIVE SUMMARY

**In accordance with Title 40, Part 194.8(b), of the** Code of Federal Regulations **[40 CFR 194.8(b)], the U.S. Environmental Protectio n Agency (EPA or the Agency) conducted**  **Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 of th e Central Characterization Project’s**  **(CCP) waste characterization (WC) program for remot e-handled (RH) transuranic (TRU) waste**  **at the U.S. Department of Energy’s (DOE) Savannah R iver Site (SRS) located in Aiken, South**  **Carolina. The waste characterized by the SRS-CCP i s RH debris waste from the**  **decommissioning of a hot cell laboratory at the Bat telle Columbus Laboratory (BCL) that was**  **shipped to SRS for characterization and disposal at the Waste Isolation Pilot Plant (WIPP). EPA**  **conducted a baseline inspection of SRS-CCP’s progra m to characterize this waste in the**  **Washington Group’s office in Denver, Colorado, on J uly 17–19, 2007 and at the DOE’s**  **Carlsbad Area Field Office (CBFO) in Carlsbad, New M exico, on July 31–August 2, 2007 and**  **December 4–5, 2007.**

**The RH waste from Battelle Columbus Laboratory Deco mmissioning Project (BCLDP) is**  **packaged in 87 drum liners 1**  **and is in interim storage at SRS. SRS-CCP charact erized this waste**  **by implementing the WC activities discussed in this report and demonstrating compliance with**  **40 CFR §194.24. SRS-CCP used the historical BCLDP- generated data to develop acceptable**  **knowledge (AK) records. EPA’s baseline inspection’ s sole focus was to evaluate the AK records**  **that had been assembled to document RH TRU WC activ ities, including recently performed**  **modeling, interpretation, and additional calculatio ns based on previously generated measurement**  **data for BCLDP RH debris Waste Stream SR-RL-BCLDP.0 01.** 

**On May 21, 2008, EPA issued a Federal Register (FR) notice proposing to approve BCL’s TRU**  **RH debris wastes for disposal at WIPP that were cha racterized using the CCP-implemented RH**  **waste characterization processes (see 73 FR 28504–2 9507). In response to the proposed**  **approval, EPA received one comment that is docketed in EPA Air Docket ID EPA-HQ-OAR**  **2008-0410 and which is included verbatim in Section 9 of this report, along with EPA’s**  **response. This comment objected to the requirement for a new baseline inspection and approval**  **of any non-BCLDP RH waste that SRS-CCP would charac terize for disposal at WIPP. Upon**  **considering and responding to the comment, EPA is f inalizing the proposed retrospective**  **approval of RH TRU debris waste for the disposal at WIPP. In addition, EPA approves the RH**  **TRU waste characterization processes discussed in t his report that SRS-CCP implemented and**  **EPA evaluated for technical adequacy. No additional RH debris waste from this BCLDP waste**  **stream, i.e., no wastes other than the 87 drum line rs discussed in this report, is approved for**  **WIPP disposal. Additionally, following this approv al, any non-debris RH waste from BCLDP**  **that SRS-CCP wishes to characterize using the appro ved WC activities discussed in this report**  **will require EPA approval as a Tier 1 (T1) change.**

**When proposing to approve the RH TRU WC processes d iscussed in the May 2008 baseline**  **inspection report, EPA stated that if SRS-CCP embar ks on characterizing RH wastes for WIPP**  **disposal other than those generated at BCLDP, a sep arate baseline inspection and approval will** 

**1 A liner is a 55-gallon rigid steel liner that fits**  **within a standard 55-gallon drum and acts as an ov erpack.**  **Specifications for drum liners are provided in Sect ion 8, and are shown in Figure 1.** **2**

**be necessary. That is, any SRS RH waste destined f or WIPP disposal that is characterized by**  **SRS-CCP or another program remains subject to EPA’s baseline inspection and approval.** 

**EPA must verify compliance with 40 CFR 194.24 befor e waste may be disposed of at the WIPP,**  **as specified in Condition 3 of the Agency’s certifi cation of the WIPP’s compliance with disposal**  **regulations for TRU radioactive waste (63** Federal Register **(FR) 27354 and 27405, May 18, 1998). EPA Baseline Inspection No. EPA-SRS-CCP-RH-0**  **7.07-8 was performed in accordance with the provisions of 40 CFR 194.8(b), as issued i**  **n a July 16, 2004, FR notice (Vol. 69, No. 136, pp. 42571–42583). The purpose of the SRS-C**  **CP RH WC inspection was to evaluate the adequacy of the site’s WC programs for 87 drum**  **liners in a single RH debris waste stream for disposal at the WIPP. The 87 drum liners of RH**  **debris in this waste stream were generated from the decontamination and decommissioning (D&D)**  **of the Building JN-1 Hot Cell Laboratory (HCL) at the West Jefferson North facilit**  **y, which operated under the BCLDP from 1955 until D&D began in 1988.** 

**EPA is finalizing the proposed approval of the foll owing WC activities:** 

**(1) The AK process for the 87 drum liners of RH retriev**  **ably stored TRU debris in the waste stream designated as Waste Stream SRS-RL-BCLDP.001**  **currently stored at the TRU storage pads in the E Area of SRS.**  **(2) The radiological characterization process using dos**  **e-to-curie (DTC) and modeling derived scaling factors, supported by radionuclide**  **data from the analysis of 69 swipe samples, for assigning radionuclide values to 87 dr**  **um liners of RH retrievably stored TRU debris in one waste stream, designated as SRS-R**  **L-BCLDP.001, that is documented in CCP-AK-LANL-501, Revision 2, and detailed in thi**  **s report.**

**(3) The visual examination (VE) process to identify was**  **te material parameters and the physical form of the waste.** 

**(4) The WIPP Waste Information System (WWIS) to submit**  **both characterization and certification data for RH TRU waste.** 

**(5) The attainment of pertinent data quality objectives**  **(DQOs).**

**Since no additional WC activities are expected to o ccur relative to the 87 drum liners of RH**  **debris waste, changes to the WC activities evaluate d during the baseline inspection are not**  **anticipated. EPA, therefore, does not expect SRS-C CP to make additional revisions to the**  **documents that were reviewed as part of the baselin e inspection and this approval is limited to**  **the WC processes specific to the 87 drum liners tha t were evaluated in July, August, and**  **December 2007. In the event that SRS-CCP makes cha nges to the EPA-approved WC**  **components discussed in this report and implements them to characterize additional waste from**  **the BCLDP activity (e.g., solids or soil/gravel) as sociated with D&D activities at Building JN-1**  **at the BCL, EPA will consider changes that have the potential to affect WC activities to be T1**  **changes, as stated above. This report does not lis t specific T1 or Tier 2 (T2) designations**  **relative to these 87 drum liners containing RH TRU debris waste from BCLDP and the WC**  **components approved at this time. SRS-CCP, however , must provide to EPA a copy of the** **3**

**WWIS controlled spreadsheet showing the manual data entries that were downloaded from CCP**  **AK-SRS-501 upon completion as a one-time T2 change.**

**As experienced at the other RH waste sites, WC acti vities implemented under the CCP program**  **are customized to site-specific RH waste streams. The applicability of RH WC techniques at one**  **site to RH wastes at other sites is such that signi ficant modifications may be required to**  **individual WC components, and the process of develo ping documentation or objective evidence**  **is site-specific (see Section 9 for further discuss ion). As stated in Section 9.0, should SRS-CCP**  **request approval of any non-BCL RH waste generated at SRS or waste brought to SRS for**  **characterization, a new baseline inspection will be necessary.** 

2.0 PURPOSE OF INSPECTION

**On May 18, 1998, EPA certified that the WIPP will c omply with the radioactive waste disposal**  **regulations in 40 CFR Part 191. In this certificat ion, EPA also included Condition 3, which**  **states that “the Secretary shall not allow shipment of any waste from...any waste generator site**  **other than LANL for disposal at the WIPP until the Agency has approved the processes for**  **characterizing those waste streams for shipment usi ng the process set forth in §194.8.” The**  **approval process described in 40 CFR 194.8 requires DOE to (1) provide EPA with information**  **on AK 2**  **for waste streams proposed for disposal at the WIP P, and (2) implement a system of**  **controls used to confirm that the total amount of e ach waste component that will be emplaced in**  **the WIPP will not exceed limits identified in the W IPP Compliance Certification Application.** 

**Under the changes to 40 CFR 194.8 promulgated in th e July 16, 2004, FR notice, EPA must**  **perform a baseline inspection of a TRU waste genera tor site’s WC program. The purpose of the**  **baseline inspection is to approve the site’s WC pro gram based on the demonstration that the**  **program’s components, with applicable conditions an d limitations, can adequately characterize**  **TRU wastes and comply with the regulatory requireme nts imposed on TRU wastes destined for**  **disposal at the WIPP. An EPA inspection team condu cts an on-site inspection to verify that the**  **site’s system of controls is technically adequate a nd properly implemented. Specifically, EPA’s**  **inspection team verifies compliance with 40 CFR 194 .24(c)(4), which states the following:** 

Any compliance application shall: . . . Provide inf ormation which demonstrates that a system of controls has been and will continu e to be implemented to confirm that the total amount of each waste component that will be emplaced in the disposal system will not exceed the upper limiting value or fall below the lower limiting value described in the introductory text o f paragraph (c) of this section. **3**

**2 As of the FR notice of July 16, 2004, EPA has repl**  **aced the term** process knowledge **with** acceptable knowledge **. Acceptable knowledge refers to any information a bout the process used to generate waste, material**  **inputs to the process, and the time period during w hich the wastes were generated, as well as data res**  **ulting from the analysis of waste conducted prior to or separate fr**  **om the waste certification process authorized by an EPA**  **certification decision to show compliance with Cond ition 3 of the certification decision.** 

**3 The introductory text of 40 CFR 194.24(c) states,**  **“For each waste component identified and assessed p ursuant**  **to [40 CFR 194.24(b)], the Department shall specify the limiting value (expressed as an upper or lower**  **limit of mass, volume, curies, concentration, etc.), and the**  **associated uncertainty (i.e., margin of error) for each limiting**  **value, of the total inventory of such waste propose d for disposal in the disposal system.”** **4**

The system of controls shall include, but shall not be limited to: Measurement; sampling; chain of custody records; record keeping systems; waste loading schemes used; and other documentation.

**In other words, the purpose of the baseline inspect ion is to implement the requirements of**  **40 CFR 194 by assessing whether DOE sites that char acterize TRU waste prior to disposal at the**  **WIPP are capable of characterizing and tracking the waste. EPA may also conduct follow-up**  **inspections to address issues remaining from the ba seline inspection or to seek further**  **clarification/discussion related to WC processes ev aluated during a baseline inspection. By**  **approving the WC systems and processes at SRS-CCP t hat were applied to the 87 drum liners of**  **retrievably stored RH debris waste, EPA confirms th at the Agency has evaluated the capabilities**  **of systems and processes implemented by the site to accomplish two tasks: (1) the identification**  **and measurement of waste components that must be tr acked for compliance such as plutonium,**  **4 and (2) the confirmation that the waste in any give**  **n container has been properly identified as belonging to the group of approved waste streams.** 

**Based on the adequacies of the WC processes demonst rated during the baseline inspection,**  **including all conditions and limitations, EPA usual ly specifies which subsequent WC program**  **changes or modifications must undergo further EPA i nspection or approval under**  **40 CFR 194.24. This is accomplished by assigning a tier level to each aspect of the**  **characterization program, i.e., T1 and T2 activitie s. However, the nature of the WC activities at**  **SRS-CCP is such that no additional characterization activities are anticipated, making a**  **prospectively orientated T1 or T2 assignment irrele vant. Accordingly, no formal tiering is**  **finalized for the SRS-CCP RH WC program at this tim e. As stated previously, EPA’s approval**  **is limited to the 87 drum liners of RH TRU wastes w hose characterization is documented in the**  **records evaluated during the inspection and detaile d in this report. Should SRS-CCP seek to**  **characterize additional RH wastes from BCLDP for di sposal at WIPP, such wastes would be**  **considered a T1 activity and would be addressed acc ordingly. The rule applying to this baseline**  **inspection can be found in the FR (Vol. 69, No. 136, pp. 42571–42583, July 16, 2004). EPA**  **does not expect to conduct additional SRS-CCP RH wa ste inspections specific to this waste**  **stream in the future. If SRS-CCP characterizes RH wastes that do not originate at BCLDP for**  **WIPP disposal, a new EPA baseline inspection and ap proval will be necessary under the**  **authority of 40 CFR 194.8.**

3.0 PURPOSE OF THIS REPORT

**This report documents the basis for EPA’s approval decision and explains the results of Baseline**  **Inspection No. EPA-SRS-CCP-RH-07.07-8 in terms of fi ndings or concerns. Specifically, this**  **report does the following:**

**4 The potential contents of a single waste stream or**  **group of waste streams determine which processes ca n**  **adequately characterize the waste. For example, if AK suggests that the waste form is heterogeneous,**  **the site should select the matrix-appropriate radiological characte**  **rization technique to obtain adequate radionuclide measurements.**  **VE serves to confirm and quantify waste components, such as cellulosics, rubbers, plastics, and metals**  **. Once the nature of the waste has been confirmed, characteriz**  **ation techniques quantify selected radionuclides in the waste. In**  **some cases, a TRU waste generator site may be able to characterize a range of heterogeneous waste stre**  **ams or only a few. A site’s stated limits on the applicability**  **of proposed WC processes govern the scope of EPA’s inspection.** **5**

• **Describes the characterization systems SRS-CCP subm itted for approval** 

• **Delineates a specific set of RH wastes submitted fo r approval** 

• **Provides objective evidence as basis for the approv al of all WC systems and/or waste**  **containers**

• **Identifies all relevant limitations and or conditio ns for each WC system and/or waste**  **container**

• **Provides objective evidence of outstanding findings or concerns in the form of**  **documentation, as applicable**

• **Describes any tests or demonstrations completed dur ing the course of the inspection and**  **their relevance to EPA’s approval decision, as appl icable** 

**The listings in each section reference the document s that the EPA inspection team members**  **reviewed in support of the technical determination. To see or obtain copies of any items**  **identified in the attached checklists, write to the following address:** 

**Quality Assurance Manager USDOE/Carlsbad Field Office**  **P.O. Box 3090 Carlsbad, NM 88221** 

**EPA’s final approval decision regarding the SRS-CCP RH WC program is conveyed to DOE**  **separately by letter. In accordance with 40 CFR 19 4.8(b)(3), this information is also available on**  **EPA’s Web site at http://www.epa.gov/radiation/WIPP**

**.**

4.0 SCOPE OF INSPECTION

**The scope of Baseline Inspection No. EPA-SRS-CCP-RH- 07.07-8 included the technical**  **adequacy of the WC systems used by SRS-CCP to chara cterize 87 drum liners of RH TRU**  **wastes in SRS RH Waste Stream SR-RL-BCLDP.001. At the start of the inspection, SRS-CCP**  **presented the number of drums in Waste Stream SRS-R L-BCLDP.001 as 88. However, SRS**  **CCP determined that one of these drums did not meet the definition of TRU waste and it was**  **removed from the waste stream directly prior to the inspection, leaving a total of 87 drums**  **within the inspection’s scope. The basis for all r adiological and physical waste characterization**  **of these 87 drums was AK, and included the identifi cation and quantification of the 10 WIPP**  **tracked radionuclides ( 241**  **Am, 137**  **Cs, 238**  **Pu, 239**  **Pu, 240**  **Pu, 242**  **Pu, 90**  **Sr, 233**  **U, 234**  **U, and 238**  **U). Accordingly, the inspection’s scope consisted of re**  **viewing records of WC activities that had been performed previously in conjunction with the B**  **CLDP, supplemented by data interpretation and manipulation, and the development and applicati**  **on of conceptual models related to WC performed more recently by SRS-CCP.** 

**During an inspection, EPA does not approve characte rization data; that function is the sole**  **responsibility of the site being evaluated during t he inspection, in this case SRS-CCP. EPA**  **evaluated records that documented the technical asp ects of the WC processes implemented by**  **SRS-CCP to characterize 87 drum liners of RH retrie vably stored debris waste that were** **6**

**conducted during the BCLDP. These records included more recent compilations of older**  **information, as well as newer interpretations of, a nd additional calculations to, older**  **measurement data. The evaluation consisted of inte rviewing personnel and inspecting records**  **related to the WC processes within the inspection’s scope. An important aspect of this**  **evaluation is the objective evidence that documents the effectiveness of the WC processes.**  **Objective evidence typically takes the form of BDRs for radiological characterization and AK**  **accuracy reports. EPA typically selects samples of each of these items based on the number and**  **variety of items that were completed and available for inspecting each WC process, consistent**  **with standard sampling techniques. However, becaus e the WC activities for these BCLDP RH**  **wastes are not ongoing, BDRs were not prepared. Ac cordingly, EPA evaluated records**  **associated with the characterization of an appropri ate sample of the 87 drum liners. EPA**  **examined WC information that was provided within sp ecific SRS-CCP reports that were the**  **equivalent of what is typically contained in BDRs. Based on an evaluation of the WC processes**  **documented in the SRS RH records, EPA determined th e technical adequacy of the WC**  **processes within the inspection’s scope.**

5.0 INSPECTION-RELATED DEFINITIONS

**During the course of an inspection, EPA inspectors may encounter items or activities that require**  **further inquiry for their potential to adversely af fect WC and/or isolation within the repository.**  **The two main categories relevant to WC inspections are identified below:** 

Finding **: A determination that a specific item or activity does not conform to** 

**40 CFR 194.24(c)(4). A finding requires a response from CBFO.** 

Concern **: A judgment that a specific item or activity may o r may not have a negative effect on** 

**compliance and, depending on the magnitude of the i ssue, may or may not require a**  **response. (Concerns not requiring a response do no t have to be addressed prior to**  **program approval.)**

6.0 PERSONNEL

6.1 EPA Inspection Team

**The members of the EPA WC inspection team are ident ified in Table 1.** 

Table 1. EPA Inspection Team Members

Inspection Team Member Position Affiliation **Ms. Rajani Joglekar Inspection Team Leader U.S. EPA ORIA**  **Mr. Ed Feltcorn Inspector U.S. EPA ORIA Ms. Connie Walker Inspector S. Cohen & Associates,**  **Inc. Ms. Dorothy Gill Inspector S. Cohen & Associates, I**  **nc. Mr. Patrick Kelly Inspector S. Cohen & Associates,**  **Inc. 7** 

6.2 Personnel Contacted

**EPA and its support personnel conducted interviews with SRS-CCP personnel in several**  **disciplines on several occasions. The personnel co ntacted represented a sample of the SRS-CCP**  **WC staff, and they are listed in Table 2, along with their affiliation**  **and technical area. This listing is comprehensive and includes personnel pre**  **sent at all meetings conducted as part of this baseline inspection.** 

Table 2. Personnel Contacted during Inspection

Personnel Affiliation Area of Expertise **Rob Tayloe CCP AK/DTC; Scaling Factors Jene Vance CCP AK/DTC; Scaling Factors**  **Keith Meger CCP AK/DTC; Scaling Factors Eric D’Amico CCP RH SPM**  **Larry Porter CCP AK, RH SPM; Scaling Factors Steve Schafer CCP AK, AKE**  **Kevin Peters CCP AK, AKE Mark Doherty CCP DTC & Scaling Factors-MS Data**  **J.R. Stroble DOE/CBFO RH TRU Waste Certification Ma nager**  **Irene Quintana CCP RH SPM Charlie Riggs CTAC Observer**  **Porf Martinez CTAC Observer**

7.0 PERFORMANCE OF THE INSPECTION

Background and History: Battelle Columbus and Sava nnah River Site

**The RH debris waste that is the focus of this inspe ction came from the West Jefferson North Site,**  **which is part of Battelle Memorial Institute (BMI), located near West Jefferson, Ohio,**  **approximately 15 miles west of the main BMI King Av enue facility in Columbus, Ohio. BMI**  **had supported the first large-scale military applic ation of nuclear power through development of**  **fuel element/assemblies design and materials. The West Jefferson North Site’s focus was**  **research in the areas of reactor fuel, control rod, and structural material studies. Since operations**  **began in the JN-1 HCL in 1955, a variety of studies relating to the radiation performance of**  **materials were conducted in the remote-handling fac ilities in Building JN-1. Experiments in the**  **JN-1 HCL consisted primarily of reactor fuel studie s that evaluated uranium, thorium, and**  **plutonium alloys and compounds; control rod materia l studies of rare-earth absorbers; and**  **evaluations of structural and cladding material. R emedial D&D activities of the West Jefferson**  **North Site facilities began in 1988 under the BCLDP for the purpose of decontaminating the**  **buildings and associated grounds such that they wou ld be suitable for unrestricted use. Battelle**  **completed the BCLDP D&D program with the final ship ments of these RH TRU waste to SRS in**  **December 2005 where they are currently stored on th e TRU Pad in E Area of SRS. SRS-CCP**  **did not perform any actual characterizations relati ve to these wastes, but instead was using the**  **BCLDP-generated data to develop AK records that sup port the WC activities for these 87 RH**  **drums. Accordingly, it was not necessary to conduc t this baseline inspection at SRS, and EPA** **8**

**conducted the review of AK records and discussions with SRS-CCP personnel in Denver,**  **Colorado. Additionally, EPA decided to evaluate th e non-destructive examination (NDE) and**  **the WWIS in CCP’s Carlsbad office for logistical re asons.** 

Inspection Process Overview

**EPA Baseline Inspection No. EPA-SRS-CCP-RH-07.07-8 h ad the scope described in Section 4.0**  **above, for the purpose of determining the site’s co mpliance with 40 CFR 194.24. The inspection**  **was conducted in the following steps:**

**(1) Obtaining and reviewing site procedures, reports, a**  **nd other technical information related to RH WC activities previously used to characterize th**  **ese wastes at BCLDP (2)**  **Preparing technical questions specific to the vario us aspects of AK prior to the inspection**  **based on the activities cited in the previous bulle t**  **(3) Interacting with CBFO and SRS-CCP personnel to arra**  **nge inspection logistics (4)**  **Evaluating SRS-CCP’s implementation of WC processes for adequacy and demonstrating**  **compliance with 40 CFR 194.24 requirements, as evid enced by the records of the WC**  **activities previously conducted at BCLDP (5)**  **Conducting the baseline inspection in Denver to ver ify the technical adequacy and/or**  **qualifications of RH WC personnel, procedures, proc esses, and equipment, as evidenced by**  **the records of the WC activities previously conduct ed at BCLDP**  **(6) Recording one finding on an EPA Inspection Issue Tr**  **acking Form, which was completed and provided to CBFO and SRS-CCP personnel as it wa**  **s generated (see Attachment A for a copy of this form)**  **(7) Communicating with CBFO and SRS-CCP personnel regar**  **ding pertinent information (8)**  **Pursuing resolution of all identified issues prior to completion of the inspection, when**  **feasible (9)**  **Conducting entrance, exit, and daily briefings for CBFO and SRS-CCP management**  **personnel (10)**  **Obtaining and reviewing SRS-CCP documents that were revised in response to the EPA**  **finding after the inspection (11)**  **Conducting additional meetings with SRS-CCP personn el to discuss the revised documents**  **and examine objective evidence for the purpose of a ddressing the technical issues**  **identified in the finding (12)**  **Issuing the inspection report and approval**

8.0 TECHNICAL EVALUATION

**EPA examined the AK process and associated informat ion to determine whether the SRS-CCP**  **RH program for characterizing Waste Stream SR-RL-BC LDP.001 from the BCLDP**  **demonstrated compliance with the requirements of 40 CFR 194.8. Due to the approach taken by** **9**

**SRS-CCP BCLDP, all WC activities relative to the 87 drum liners in this waste stream fall under**  **the general heading of AK. In this report, AK is d ivided into five sections:** 

• **8.1, Acceptable Knowledge Overview and Process Anal ysis** 

• **8.2, Radiological Characterization**

• **8.3, Physical Form and Prohibited Item Characteriza tion – Visual Examination** 

• **8.4, WIPP Waste Information System**

• **8.5, Attainment of Data Quality Objectives**

**This report format differs from the format that EPA generally uses for baseline inspection**  **reports, where there are multiple sections named fo r each WC process, i.e., AK, NDA, NDE, and**  **WWIS. Such a format reflects that the WC activitie s evaluated during the inspection are**  **ongoing and are expected to continue upon approval of the site’s WC program. The nature of the**  **SRS-CCP program is different in that all WC activit ies have occurred and there are no further**  **ongoing WC activities upon approval. The basis for all WC activities consists of records of**  **previously conducted activities, and accordingly, a ll this information is considered AK.**  **However, the actual information may consist of exam inations of the waste using both NDA and**  **NDE, in addition to historical information regarding the waste’s nature and origin.** 

Waste Containers

**All BCLDP wastes were loaded into 55-gallon steel d rum liners (a rigid liner that essentially fits**  **within a 55-gallon drum which acts as overpack). O nce the liners were full, lids were installed**  **and the liners were transferred into U.S. Departmen t of Transportation (DOT)-approved**  **containers. This report uses the term** RH drum liner **or** waste liner **, which requires clarification. Any use of the term**  liner **in this report means a steel container that fits inside a standard**  **55-gallon drum. Each liner has the following dimen sions: 0.105 inch thick, 32.250" high, with**  **an outer diameter of 22" and an inner diameter of 1 9.5", as shown in Figure 1. Each liner was**  **sealed once it was full of waste, and 82 of the sea led liners were transferred to DOT-approved,**  **UN/1A2/X400/S/99 55-gallon drums equipped with Nucfi l-013 filters (vented). Five additional**  **steel liners were loaded directly into two 72-B RH TRU canisters; three in one canister and two**  **in the other canister. The total waste stream popu lation consists of these 87 drum liners referred**  **to throughout this report. In some cases, this rep ort cites objective evidence (i.e., BCLDP or**  **SRS-CCP reports) that uses the terms** waste container **or** waste drum **, both of which are synonymous with the term**  liner

**. 10** 

Figure 1. Configuration and Dimensions of a 55-Gal lon Drum TRU RH Liner**11**

Waste Origin and Generation

**The RH debris in this waste stream was generated fr om the D&D of Building JN-1 in the West**  **Jefferson North Site of BCL in Columbus, Ohio. 5**  **The JN-1 HCL was dedicated to reactor fuel research and material evaluation in support of DOE**  **and other federal agencies. Remedial activities of the West Jefferson North facilities be**  **gan in 1988 under the BCLDP and continued until the final shipment of BCLDP D&D wastes to SRS**  **was made in December 2005. The BCLDP generated a total of 135 55-gallon drums [app**  **roximately 29 cubic meters (m 3**  **)] of RH wastes, 48 of which are not within the scope of thi**  **s inspection and are currently stored at DOE’s Hanford Site in Richland, Washington.**  **6 The remaining 87 drums of waste that are the subj**  **ect of this inspection are composed of 82 individual 55-ga**  **llon drums and 5 additional 55-gallon drums that are contained in two 72B RH Casks, 3 drums in**  **1 cask and 2 drums in the other cask, all of which are currently stored at the TRU Storage Pad i**  **n E Area of SRS. The waste components include cellulosics, plastic, rubber, glass, and me**  **tal, and less than 50% by volume in any one container consists of homogeneous organic and inorg**  **anic materials. Radionuclide components of the waste include**  **241 Am,**  **238 Pu,**  **239 Pu,**  **240 Pu,**  **241 Pu,**  **242 Pu,**  **234 U,**  **235 U,**  **238 U,**  **137 Cs, and**  **60 Co. The**  **scope of this inspection was the 87 drum liners of RH wastes currently stored at SRS and does**  **not include the 47 additional 55-gallon drums of BC LDP wastes that are in storage at Hanford.** 

**The approval of additional BCLDP drum liners at Han ford or any other location will require a**  **separate baseline inspection at such time that the site decides to characterize these wastes for**  **disposal at WIPP. The wastes to which this approva l applies are discussed in this report and**  **were generated by the BCLDP. The fact that these w astes are stored at SRS has no bearing on**  **characterization activities performed on any other contact-handled (CH) or RH TRU materials at**  **SRS or any other DOE site. Should DOE notify EPA t hat there are additional containers of RH**  **TRU wastes from the BCLDP for disposal at WIPP apar t from the 87 liners discussed in this**  **report, EPA would address the situation as a T1 cha nge, as discussed previously. However, such**  **an option would apply only to BCLDP wastes (such as solids or soil/gravel) that have waste**  **generation and WC elements in common with the 87 li ners described in this report.** 

Waste Characterization Overview

**Acceptable knowledge provides the basis for all rad iological and physical WC information. In**  **the case of this specific SRS RH waste stream, wast es were grouped using AK into a debris**  **waste stream of 87 drum liners generated through D& D of the JN-1 HCL. As part of the**  **inspection, EPA reviewed the following with respect to the use of AK for WC:** 

• **Waste stream definition and identification, includi ng radiological content** 

• **Identification of TRU versus non-TRU wastes, i.e., high-level waste (HLW) and spent**  **nuclear fuel (SNF)**

**5 The West Jefferson North Site included: Building**  **JN-2 (Critical Assembly Laboratory); Building JN-3 (Research Reactor Building); and Building JN-4 (Plu**  **tonium Laboratory). This waste stream only include s wastes**  **from JN-1.**

**6 Forty seven of these drums are stored at Hanford a**  **nd the one drum that SRS-CCP excluded from this was te**  **prior to this inspection is stored at SRS. 12** 

• **Identification and quantification of the waste’s ra dionuclide content, including**  **uncertainty**

• **Defense waste status**

• **Waste Material Parameters (WMP)**

• **Assignment of waste matrix codes (WMC)**

• **Role of AK in the characterization methodology, wit h the determination of quality**  **assurance (QA) equivalency (addressed outside of th is report), peer review, or**  **confirmation via modeling used as verification tech niques** 

• **Compilation of AK documentation and assembly of req uired information** 

• **Adequacy of the Waste Characterization Program Impl ementation Plan (WCPIP) AK**  **process implementation and AK summary report**

• **AK data traceability for all drums and containers u sed in the process from data assembly**  **through confirmatory modeling**

• **AK source document sufficiency**

• **WCPIP interpretation with respect to AK qualificati on** 

• **Confirmatory Test Plan (CTP) preparation and plan a dequacy** 

• **Characterization Reconciliation Report (CRR) prepar ation and report adequacy** 

• **Correlation and Surrogate Summary Form and CH-RH co rrelation** 

• **Personnel training**

• **AK discrepancy resolution (DR)**

• **AK accuracy**

• **Implementation of load management**

• **Physical form and prohibited item characterization using VE** 

• **WWIS**

• **Identification of the method for determining DQOs, including those to be attained by AK**  **qualification**

**Waste Stream SR-RL-BCLDP.001 has been characterized by AK that was qualified through a**  **determination of QA equivalency (not addressed in t his report). Because the characterization**  **process is based solely on AK records and the vario us methods used to verify AK exclusive of**  **confirmatory testing, the entire inspection was bas ed on reviewing documents of activities that**  **had been completed prior to the inspection. BDRs w ere not prepared to meet WCPIP**  **requirements, and observations of procedural implem entation could not be made because all**  **characterization activities had been completed prio r to the inspection. No further testing or**  **characterization of the 87 drum liners will be perf ormed.** **13**

**Radiological information available for this waste s tream includes the radiochemical analytical**  **results of 69 swipe 7**  **samples taken at various locations within JN-1, as well as a memorandum**  **presenting 235**  **U enrichment, burn-up, and decay for light-water re actor (LWR) fuel pins.**  **External exposure rate (dose rate) 8**  **measurements were taken at the time of packaging f or all**  **drum liners. The determination of several DQOs was achieved through use of radionuclide**  **specific scaling factors and isotopic distributions that were applied to dose rate data derived by**  **applying the DTC technique for each drum liner. Th e scaling factors were derived using**  **ORIGEN2.2 9**  **modeling with input based on attributes of LWR fue ls that were assumed to**  **contribute the majority of the waste stream’s radio nuclide content. Radionuclide data from the**  **analysis of swipe samples taken throughout the JN-1 facility were used to support the scaling**  **factors derived with ORIGEN2.2 for plutonium and ame ricium isotopes and specific fission**  **products.** Documents Reviewed

**The list of documents provided below includes all d ocuments related to the SRS-CCP RH**  **radiological characterization program that were eva luated to support this inspection:** 

• **C001, Interview Record: Eugene Sands, Master Resea rch Technician; Larry Stickel, Master**  **Technician; Harley Toy, Manager of Regulatory Compl iance and Technical Services; Max**  **Berchtold, JN-1 Lab Technician; George Kirsch, Heal th Physicist; K.J. Peters and J.**  **Harrison, May 1, 1998**

• **C002, Packet of Letters Concerning Destruction/Immo bilization of Toxic Substances by**  **Intense Gamma Irradiation, L. M. Lowry, H. L. Toy, E. W. Ungar, R. DiSalvo, November 8,**  **1982, December 13, 1982, December 15, 1982, January 27, 1983** 

• **C003, Letter to Louis B. Myers, re: Characterizatio n of the JN-1 Hot Cell Waste Drums, M.**  **P. Failey, May 1, 1997**

• **C004, Interview Record: Harley Toy, Manager of Regu latory Compliance and Technical**  **Services; George Kirsch, Health Physicist, Historic al Operations in JN-1, K.J. Peters, July**  **12, 1998**

• **C005, Interview Record: Scott Kitts, Manager Specia l Waste Projects, Hanford N-Reactor**  **Process Tube in JN-1, K.J. Peters, July 16, 1998**

• **C006, Interview Record: Max Berchtold, JN-1 Lab Tec hnician, Historical Operations in JN-1** 

**7 The terms**  swipe **and** smear **refer to a small piece of absorbent material that is wiped or smeared on a surface**  **area and subsequently analyzed by destructive or no ndestructive radiometric techniques to estimate the**  **amount of removable radioactive contamination on the area or**  **item that was wiped. Standard Health Physics pract ices**  **typically express swipe/smear results in activity u nits per area or per swipe, e.g., μCi/100 cm**  **2 or dpm/swipe.**  **Consistent with the usage observed in the BCLDP doc uments reviewed during this inspection, these two t**  **erms are used interchangeably in this report.** 

**8 Although the terms**  dose rate

**,** dose equivalent rate **, and** external exposure rate **have different meanings, they are sufficiently similar in this context to allow t**  **heir use interchangeably in this report. The most prevalent**  **terminology used to express this waste attribute in BCLDP documents is**  dose rate **, stated in milliRoentgens per hour (mR/hr), which for our purposes is the equival**  **ent of** dose equivalent rate **expressed in mRem/hr from the standpoint of determining a container’s RH status.** 

**9 The computer code used is ORIGEN2, Version 2.2, wh**  **ich is expressed as ORIGEN2.2 throughout this repor t.** **14**

**and Hydraulic Oil Composition (including MSDS), K.J . Peters, July 15, 1998** 

• **C007, Interview Record: Scott Kitts, Manager Speci al Waste Projects, Separation of Hot**  **Cell Waste from Wastes from Supporting Areas, K.J. Peters, July 22, 1998** 

• **C008, Memorandum to Mike Brown, re: Certification S trategy for Transuranic Waste**  **Generated from the Battelle Columbus Laboratories D ecommissioning Project, C98-065,**  **Various, June 25, 1998**

• **C021, Letter to AK Record, re: Estimates of Waste S tream Generation Volumes and Waste**  **Material Parameter Categories for Building JN-1 Rep ackaged Waste, K.J. Peters, May 7,**  **1999**

• **C033, Letter to Contractors, Richland, Washington; Director, Pacific Northwest Laboratory;**  **President, Westinghouse Hanford Company, re: Spent Nuclear Fuel Records, 96-SFD-059,**  **E.D. Sellers, March 14, 1996**

• **C034, Memorandum to Elizabeth D. Sellers, re: Natio nal Spent Nuclear Fuel Program**  **Evaluation of Hanford Building 327 Material for App licability of RH-TRU Waste Criteria**  **for Disposal at WIPP, OPE-SFP-081, J. Boyd, March 2 4, 1997** 

• **C035, Letter to H. J. Hatch, re: Contract No. DE-AC0 5-96RL13200 - Classification of**  **Nuclear Materials in the 327 Building, 97-SFD-074, E .D. Sellers, April 21, 1997** 

• **C047, Letter to Pete Erickson, re: Findings on the Result of Pressure Wash Decontamination**  **on the JN Waste Matrix, C. Jensen and J. Sarge, July 25, 2000** 

• **C501, Battelle Defense Determination Approval, E. R ose, July 15, 2005** 

• **C502, Surveillance (S-01-37) of the Battelle Columb us Laboratories Decommissioning**  **Project (BCLDP) Remote Handled Waste Characterizati on, CBFO:QA:TJR:VW:01-**  **1451:UFC:2300, T. Baillieul, September 17, 2001**

• **C504, Waste Material Parameter Weight Evaluation fo r Waste Stream SR-RL-BCLDP.001,**  **K.J. Peters, April 11, 2007**

• **C505, U.S. DOE CAO Audit Report of the Battelle Col umbus Laboratories**  **Decommissioning Project, TRU Waste Characterization Activities Related to Acceptable**  **Knowledge, May 7, 1999, Audit Number A-99-15, M.A. I taliano, June 4, 1999** 

• **DR002, Interview Record for Discrepancy Report of G eorge Kirsch, re: Date of the**  **Beginning of Operations of the HEC and Pool, K.J. P eters, July 28, 1998** 

• **DR004, Interview Record of Cidney Voth, re: Evapora tion of the JN-1 Transfer/Storage Pool**  **Water, K.J. Peters, April 27, 1999**

• **DR005, Letter to AK Record, re: Discrepancy Report Relating to Lead Detected in Sample of**  **Pool Water, K.J. Peters, May 12, 1999**

• **DR006, Letter to AK Record, re: Discrepancy Report Relating to RCRA Metals Detected in**  **Samples Pool Resins and Filters, K.J. Peters, June 29, 1999** 

• **DR009, Letter to AK Record, re: Discrepancy Report Regarding Generation of Four Debris**  **Waste Streams, 5190-01, 5190-02, 5390-01, and 5390- 02, K.J. Peters, May 25, 2001** **15**

• **DR010, Letter to AK Record, re: Discrepancy Report Relating to RCRA Metals Detected in**  **Pool Resins and Filters Samples, and TRU Resin Volu me Estimation, S.M. Smith, May 25,**  **2001**

• **DR011, RCRA Hazardous Waste Number Assignment Discre pancy Report, K.J. Peters, Date**  **TBD**

• **P002, Fuel Storage Pool, Pump Room, and Washdown Ro om JN-1B. Decontamination and**  **Decommissioning Operations, L.B. Myers, M.B. Bercht old, and J.L. Stickel, July 1, 1995** 

• **P003, High Energy Cell, Mezzanine, and Top of HEC J N-1B. Decontamination and**  **Decommissioning Operations, L.B. Myers, M.B. Bercht old, P.D. Faust, and P.A. Tomlin,**  **December 1, 1994**

• **P004, Waste Storage Shed JN-1A. Decontamination an d Decommissioning Operations, L.B.**  **Myers and M.B. Berchtold, June 1, 1995**

• **P005, Hot Cell Purposes and Activities. Decontamin ation and Decommissioning Operations,**  **Battelle Columbus Laboratories, September 22, 1997**

• **P006, Contents of the West Jefferson North Hot Cells and Storage Areas, L.B. Myers, M.B.**  **Berchtold, and E.H. Sands, May 1, 1995**

• **P008, West Jefferson North Hopper Location and Conte nts, L.B. Myers and M.B. Berchtold,**  **June 1, 1995**

• **P009, Chemistry Laboratory, Counting Room and Micro probe Room, L.B. Myers, M.B.**  **Berchtold, P.A. Tomlin, and M.P. Failey, December 1 , 1994** 

• **P010, Evaporator Room JN-1A, Louis B. Myers, M.B. B erchtold, and P.A. Tomlin,**  **November 1, 1994**

• **P011, Controlled Access Area Storage Rooms JN-1A, L .B. Myers, M.B. Berchtold, P.D.**  **Faust, and P.A. Tomlin, October 1, 1994**

• **P012, Controlled Access Area JN-1A, L.B. Myers, M.B . Berchtold, P.D. Faust, and P.A.**  **Tomlin, September 1, 1994**

• **P013, Mezzanines JN-1A, L.B. Myers and M.B. Berchto ld, September 1, 1994** 

• **P014, Mechanical Test Cell JN-1A, L.B. Myers, C.A. Redd, Sr., and M.B. Berchtold, July 1,**  **1994**

• **P015, High Level Cell and Low Level Cell Hydraulic Doors and Hydraulic Door Room JN**  **1A, L.B. Myers and M.B. Berchtold, September 1, 199 4** 

• **P016, Subcells of the High Level and Low Level Cell s in JN-1A, L.B. Myers, M.B.**  **Berchtold, and P.A. Tomlin, November 1, 1994**

• **P017, Low Level Cell JN-1A, L.B. Myers, M.B. Bercht old, T.A. Beddick, P.D. Faust, and**  **P.A. Tomlin, August 1, 1994**

• **P018, High Level Cell JN-1A, L.B. Myers, M.B. Berch told, P.D. Faust, and P.A. Tomlin,**  **August 1, 1994 16** 

• **P019, Charpy Room JN-1A, Louis B. Myers, C.A. Redd, Sr., M.B. Berchtold, June 1, 1994** 

• **P023, Course 7: Metals for Nuclear Power, Lesson Te n: Structural Materials, Metals**  **Engineering Institute, 1958**

• **P025, Miscellaneous Material Safety Data Sheets (MS DS), Various** 

• **P026, The U.S. Government and Battelle: Partners i n Nuclear Research, 1943 - Present,**  **Various, Not Given**

• **P028, Battelle Columbus Laboratory Hot Cell Facilit y, Radioactive Material Receipt Record**  **and Survey, Project G-7656-3, T.R. Emswiler, Octobe r 24, 1967** 

• **P029, Battelle Memorial Institute - Columbus Labora tory, Radioactive Shipment and Receipt**  **Form, Project 227566, T. R. Emswiler, December 24, 1970** 

• **P032, Procedures Manual for Battelle’s Radioisotope , Gamma, and Hot-Cell Laboratories,**  **BMI-PM-662, D.N. Sunderman and R.F. Dickerson, Febru ary 20, 1962** 

• **P034, Finding of No Significant Impact and Environme ntal Assessment, Battelle Columbus**  **Laboratories Decommissioning Project, U.S. DOE Chic ago Operations Office, June 1, 1990** 

• **P037, Decontamination Work Plan for Building JN-1, Battelle Columbus Division,**  **November 1, 1990**

• **P041, Interim Guidance on Ensuring that Waste Quali fies for Disposal at the Waste Isolation**  **Pilot Plant, U.S. DOE CBFO, December 13, 1997**

• **P076, Acceptable Knowledge Summary, Pool Water Pref ilter and Debris, Revision 1,**  **WASTREN, Inc., January 19, 2001**

• **P077, Waste Management Operating Procedure: Operat ion and Maintenance of the Alkota**  **Pressure Washer, WA-OP-061, Revision 3, Battelle Co lumbus Laboratories, March 6, 2001** 

• **P078, Work Instruction: Operation of CAA Pressure W ash System, WI-976, Revision 2,**  **Battelle Columbus Laboratories, November 30, 2000**

• **P079, Work Instruction: Material Removal from the High Level Cell, WI-1021, Revision 0,**  **BCL, February 2, 2001**

• **P501, Building JN-1 Hot Cell Laboratory Acceptable Knowledge Document, TCP-98-03,**  **Revision 2, K. J. Peters, August 2001**

• **P503, Waste Characterization Classification, and Sh ipping Support Technical Basis**  **Document for BCLDP West Jefferson North Facility, DD -98-04, Revision 4, C. W. Skapik,**  **November 2002**

• **P505, Segregation and Packaging of TRU Waste, TC-OP -01.4, Revision 2, P. Erickson, Date**  **TBD**

• **P506, Packaging Video Documentation, TC-OP-01.5, Re vision 2, D. Garber, Date TBD** 

• **P511, Technical Basis Document, Acceptable Knowledg e Process Description, Repackaging**  **of Building JN-1 Clean-Up Waste Containers, TCP-98- 03.1.2, Revision 2, K.J. Peters,**  **WASTREN, Inc., July 2001 17** 

• **P512, Technical Basis Document, Acceptable Knowledg e Process Description, TRU Waste**  **Laundry Decontamination, TCP-98-03.1.3, Revision 1, K.J. Peters, WASTREN, Inc., June**  **2001**

• **P514, Identification, Segregation, Separation, and Documentation of Low Level and**  **Radioactive Mixed Waste, WA-OP-020, Revision 7, P. Erickson, Date TBD** 

• **P518, Lessons Learned Report for the BCLDP Transura nic Waste Shipments to Hanford and**  **the Savannah River Site for Interim Storage and Fin al Characterization, N/A, P. Weaver,**  **November 2006**

• **P704, Characterization of Remote-Handled Transurani c Waste for the Waste Isolation Pilot**  **Plant – Final Report, National Academy of Sciences, 2002** 

• **P727, CCP Calculation Cover Sheet: SRS TRU Radiolog ical Characterizations, SRS-RH-01,**  **Revision 0, R. Tayloe, June 26, 2007**

• **P729, Swipe Sample Data Analysis Calculation Packag e, SRS-RH-03, Revision 0, J. Vance,**  **May 16, 2007**

• **P735, Fuel Type Evaluation, SRS-RH-09, Revision 0, J. Vance, May 16, 2007** 

• **P737, Calc Package for Determination of Reportable Isotopes, SRS-RH-11, Revision 0, J.**  **Vance, May 16, 2007**

• **U001, Miscellaneous Maps of Battelle Columbus West Jefferson North Facility, Battelle**  **Columbus Laboratories, Date Not Given**

• **U002, Description of the Battelle Hot Cell Laborato ry, Battelle Columbus Laboratories, Date**  **Not Given**

• **U003, Battelle-Columbus Hot Cell Laboratory - Capab ility Summary, Battelle Columbus**  **Laboratories, Date Not Given**

• **U004, Buildings JN-1, JN-2, and JN-3 Summaries, Bat telle Columbus Laboratories, Date**  **Not Given**

• **U006, ENG-92 Contract Projects Database 1 Printout, Query Dated May 20, 1985** 

• **U008, Nuclear Fuel Inventory at West Jefferson North, Battelle Columbus Laboratories, Date**  **Not Given**

• **U009, Miscellaneous JN-1 Waste Inventory Data, Batt elle Columbus Laboratories,**  **1988**

− **1997**

• **U014, ENG-92 Contract Projects Database 2 Printout, Battelle Columbus Laboratories,**  **Query, October 17, 1986**

• **U016, Nuclear Materials Questionnaires, Battelle Col umbus Laboratories, 1985** 

• **U025, Actinide Screen Data for Radionuclides Contai ned in Strippable Paint from JN-1**  **Charpy Cell, Battelle Columbus Laboratories, July 1 7, 2000** 

• **U026, 69 Sample Basis of DD-98-04 Technical Basis D ocument, Battelle Columbus**  **Laboratories, May 25, 2001 18** 

• **U509, Waste Management 2000 Presentation and Paper – RH-TRU Waste Packaging Visual**  **Confirmation Using a Dual-Camera Video Security and Documentation System, D. Garber,**  **J. Eide, and K. Peters, Not Dated**

• **U513, Miscellaneous Inventory Spreadsheets, K.J. Pe ters, BCLDP, SRS, Hanford, Various** 

• **U516, Waste Management 2002 Paper, Adequacy of a Sm all Quantity Site RH-TRU Waste**  **Programs in Meeting Proposed WIPP Characterization Objectives, J. Biedscheid, M.**  **Devarakonda, S. Stahl, K. Peters, and J. Eide, 2002**

• **U734, Review of Spreadsheet WJ_samp.xls “69 Swipes from Battelle”, R. Tayloe, August 7,**  **2001**

• **CCP-AK-SRS-500: Central Characterization Project Ac ceptable Knowledge Report for**  **Battelle Columbus Laboratory’s Decontamination Proj ect (BCLDP) Remote Handled**  **Transuranic Debris Waste from the Building JN-1 Hot Cell Laboratory, Waste Stream: SR**  **BL-BCLDP.001, Revision 0, May 17, 2007 and Revision 1, August 27, 2007** 

• **CCP-AK-SRS-501: Central Characterization Project Re mote Handled Transuranic**  **Radiological Characterization Technical Report for Remote Handled Transuranic Debris**  **Waste from Battelle Columbus Laboratory’s Decontami nation Project at the West Jefferson**  **North Facility, Revision 0, June 14, 2007 and Revisi on 2, November 28, 2007** 

• **CCP-AK-SRS-502: Central Characterization Project RH TRU Waste Certification Plan for**  **40 CFR Part 194 Compliance and Confirmation Test Pl an for BCLDP Waste Stream SR-RL**  **BCLDP.001, Revision 0, June 11, 2007**

• **CCP-AK-SRS-503: Central Characterization Project Ba ttelle Columbus Laboratory**  **Decommissioning Project Quality Assurance Equivalen cy Report and Procedure Matrix for**  **Remote–Handled Transuranic Debris Waste, Revision 0 , June 13, 2007** 

• **CCP-TP-506, CCP Preparation of the Remote-Handled T ransuranic Waste Acceptable**  **Knowledge Characterization Reconciliation Report, R evision 2** 

• **Characterization Reconciliation Report, BC SRS Wast e Stream - SR-RL-BCLDP.001,**  **Attachment 5 and related required documents, prepar ed July 17, 2007 (Waste Stream Profile**  **Form, Draft, also provided)**

• **TRU Waste Package Loading Record, BC0048, February 24, 2003** 

• **Qualification Cards for S. Nance, AK Expert (AKE) an d R. Tayloe (DTC Technical**  **Specialist), provided July 19, 2007**

• **Project Office Data Tracking System (PTS), CTS Corr ective Action Non Conformance**  **Reporting, provided July 19, 2007**

• **Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, DOE/WIPP- 02-**  **3122** , **Revision 6, November 16, 2006**

• **Remote-Handled TRU Waste Characterization Program I mplementation Plan, DOE/WIPP -**  **02-3214, Revision 0D**

• **Scaling Factor Development, Calculation Package No. SRS-RH-01 Revision 0, June 26,**  **2007 and Revision 2, November 6, 2007 19** 

• **Dose-to-Curie Correlation for Cs-137 and Co-60, Cal culation Package No. SRS-RH-02,**  **Revision 0, June 26, 2007 and Revision 1, November 5 , 2007** 

• **Evaluation of Swipe Sample Data, Calculation Packag e No. SRS-RH-03, Revision 0, June**  **26, 2007 and Revision 1, October 26, 2007**

• **Source Uncertainty Using MCNP5, Calculation Package No. RSR-RH-04, Revision 0, May**  **16, 2007 and Revision 1, November 7, 2007**

• **Dose-to-Curie Spreadsheet, Calculation Package No. S RS-RH-05, Revision 0, May 16, 2007**  **and Revision 1, November 7, 2007**

• **Uncertainty Analysis, Calculation Package No. SRS-RH -06, Revision 0, May 16, 2007 and**  **Revision 1, November 7, 2007**

• **ORIGEN2.2 Benchmarking for LWR Fuel, Calculation Pa ckage No. SRS-RH-07, Revision**  **0, May 16, 2007**

• **Evaluation of Different Fuel Type, Calculation Pack age No. SRS-RH-09, Revision 0, May**  **16, 2007 and Revision 1, November 5, 2007**

• **Evaluation of Different Fuel Type, Calculation Pack age No. SRS-RH-09,** 

• **Swipe Sample Data Decay Correction, Calculation Pac kage No. SRS-RH-10, Revision 0,**  **June 26, 2007 and Revision 1, November 5, 2007**

• **Determination of Reportable Isotopes, Calculation P ackage No. SRS-RH-11, Revision 0,**  **May 16, 2007 and Revision 1, November 6, 2007**

• **Swipe Sample Data Input Check, Calculation Package No. SRS-RH-12, Revision 0, May 25,**  **2007**

• **Fission Product Contribution to Dose Rate, Calculat ion Package No. SRS-RH-13, Revision**  **0, May 25, 2007 and Revision 1, November 5, 2007**

• **ORIGEN2.2 Date Extraction Program (OriOout01), Calc ulation Package No. SRS-RH-14,**  **Revision 0, May 29, 2007**

• **TC-OP-01.4, Revisions 1 and 2**

• **TCP-98-05, Revision 3, Training Plan for the Battel le Columbus Laboratories**  **Decommissioning Project (BCLDP) TRU WCP, March 3, 2 003** 

• **Training Program, TRU 100, WIPP Indoctrination for the BCLDP TRU WCP Training**  **Program Record, Revision 2, June 15, 2000**

• **Work Instruction WI-958, Set Up and Packaging of Tr ansuranic Waste in the High Energy**  **Cell, Revision 2, April 1, 2000**

• **Work Instruction 956, Packaging of Transuranic Wast e in the Mechanical Test Cell**  **Addendum 1, March 1,1999**

• **List of Containers in Waste Stream SR-RL-BCLDP.001**

• **TRU Waste Packaging Loading Record Itemized Data, C ontainer No. BC0090** **20**

• **TRU Waste Packaging Loading Record Itemized Data an d Audio/Visual recording,**  **Container No. BC0070**

• **TRU Waste Packaging Loading Record Itemized Data an d Audio/Visual recording,**  **Container No. BC0035**

• **TRU Waste Packaging Loading Record Itemized Data an d Audio/Visual recording,**  **Container No. BC0051**

• **TRU Waste Packaging Loading Record Itemized Data an d Audio/Visual recording,**  **Container No. BC0120**

• **Training Record for VE Operator for Procedure TC-OP -01.4, Revision 2** 

• **Record Inventory and Disposition System (RIDS) for BCLDP from PR-AP-17.1, Revision 5** 

• **WIPP Waste Container Report for Canister ID0051 Hou sing Container Nos. 001131,**  **001141, and 001143**

• **WIPP Waste Container Report, Container No. 001131**

• **WIPP Waste Container Report, Container No. 001141**

• **WIPP Waste Container Report, Container No. 001143**

• **WWIS Data Entry Summary Spreadsheet, Container No. 0 01131** 

• **RTR Data Sheet, Container No. 001131**

• **Dose-to-Curie Data sheet, Container No. 001131**

• **CAR/NCR Email for INL RH Lot 9**

• **Waste Container Data, Container No. 001117**

8.1 Acceptable Knowledge Process Overview and Analysis

**(1) Waste stream definition for SRS-CCP BCLDP waste str**  **eam SR-RL-BCLDP.001 was examined and found to be adequate following incorpo**  **ration of additional information.**

**The WCPIP defines** waste stream **as “waste material generated from a single process or activity,**  **or as waste with similar physical, chemical, and ra diological properties.” Waste Stream**  **SR-RL-BCLDP.001 is a debris waste stream generated in the JN-1 HCL facility during D&D**  **activities performed from May 1999 through August 2 004, and was packaged in June, consisting**  **of 87 drum liners.**

**The EPA inspection team evaluated the physical and radiological compositions of the waste with**  **respect to waste stream definition to ensure they w ere appropriate. Several references were**  **examined to understand the historical AK assessment of the stream, including, but not limited to,**  **P501, C001, P023, P026, P511, P514, and U513. It w as noted that the waste stream was**  **generated solely through D&D of the JN-1 HCL, which included several areas, such as the**  **Mechanical Test Cell, High-Energy Cell, Low-Energy Cell, Alpha-Gamma Cells, Controlled**  **Access Area, and Charpy Room. Wastes generated inc luded the spectrum of D&D-related** **21**

**debris materials. Reference C504 summarized the WM P content within each drum liner. All**  **waste in the drum liners had been mechanically comp acted during loading to reduce void space**  **and maximize waste packaging using a 5,000-pound we ight.** 

**It was also noted that this waste stream includes f our liners that contained mop heads, as well as**  **residual solidified materials representative of sma ll fines or the solidification of liquids**  **associated with mop heads and other clean-up materi als. While the WMPs in these four liners**  **are distinguishable from the remaining D&D waste po pulation, EPA concluded that the four**  **drums containing mop heads and related materials we re generated by the same process and**  **should contain the same general material and radiol ogical parameters, so inclusion of the drums**  **in the stream was appropriate. The Acceptable Know ledge Experts (AKEs) interviewed stated**  **that no individual drum liner contained greater tha t 50% solidified material, so the waste**  **summary category group (SCG) was consistent within the waste stream, as presented in**  **reference C504.**

**The EPA inspection team determined that the AK reco rd for this waste stream was initiated years**  **prior to completion of waste packaging. For exampl e, AK document P501 was prepared in 2001**  **and described at least nine separate waste types ba sed on physical form. The EPA inspection**  **team also found that while SRS-CCP considered the d ebris in this stream to have originated from**  **a single process similar in material, chemical, and radiological properties, BCL representatives**  **packaging the waste during the clean-up process seg regated the waste into four separate**  **groupings: hazardous combustibles; non-hazardous c ombustibles; hazardous non-combustibles;**  **and non-hazardous non-combustibles. The EPA inspec tion team determined that additional**  **justification and information pertinent to waste st ream packaging and waste stream**  **determination were required to better support CCP’s conclusion to combine the 87 drum liners**  **into a single waste stream.**

**As part of EPA’s assessment of the waste stream det ermination, the EPA inspection team tracked**  **and verified several elements of the AK summary (CC P-AK-SRS-500) and its references to**  **ensure that radiological characterization performed was technically supported, with particular**  **emphasis on AK parameters used to develop the JN-1 Standard Isotopic Mix and scaling factors.**  **CCP-AK-SRS-500 presents the JN-1 Standard Isotopic Mix, citing P503 and U516 as among the**  **primary references supporting the determination of this mix. However, P503 has only a general**  **discussion of the isotopic mix determination and do es not provide detailed supporting**  **information, and U516 contains proceedings from a p resentation given at a Waste Management**  **conference in 2002. The EPA inspection team found that the memorandum documenting**  **235 U**  **enrichment, burn-up, and decay was not verified thr ough supporting references or other**  **information. The SRS-CCP AKE stated that some of t he original BCL information was not**  **available, and that they could not produce a histor ic database that cataloged the radiological**  **experiments and parameters relative to the activiti es within JN-1.** 

**Some references contain worthwhile information, suc h as U014. The EPA inspection team also**  **determined that the representativeness of the 69 sw ipe samples used to generate the radionuclide**  **scaling factors was not adequately supported in the AK record. The EPA inspection team**  **determined that it was necessary to better document the origin of**  **235 U enrichment, and the burn**  **up and decay values used as input to ORIGEN2.2 model ing in SRS-CCP documents. EPA** **22**

**discussed the need for better documentation of the origin of**  **235 U enrichment with AKEs, and**  **also issued EPA Finding No. SRS-RH-AK-07-001F, which included a number of technical**  **elements. This was the single finding of the inspe ction and it is discussed in Sections 8.1 and 8.2**  **of this report. The aspects that pertain to waste stream determination and radiological**  **characterization are presented below.**

EPA Finding No. SRS-RH-AK-07-001F **: This finding covers four issues. Table 3 indica tes**  **where each issue is addressed, identifies the repor t section where the information provided by**  **SRS-CCP is discussed, and gives the status of the i ssue. For a full description of this finding, see**  **Attachment A to this report.**

Table 3. Details of EPA Finding No. SRS-RH-K-07-00 1F

EPA Finding No. SRS-RH-AK-07-00F Issue Summary Report Section Where Issue is Discussed Issue Status

**Issue (a) Completeness and adequacy of**

**documentation for AK and radiological characterization**  **Section 8.1 (1), page 23 Resolved**

**Issue (b), 1 st** 

**bullet Limit waste stream documentation to 87**

**drum liners at SRS Section 8.1 (3), page 26 Resolved** 

**Issue (b), 2 nd** 

**bullet Clarify isotopic distributions Section 8.1 (3), page 26 Resolved** 

**Issue (b), 3 rd** 

**bullet Expand discussion of radiological**

**characteristics of waste stream Section 8.1 (3), page 26 Resolved** 

**Issue (c) Delineation of waste stream Section 8.1 ( 1), page 23 Resolved** 

**Issue (d) Documentation of TMU and radionuclide**

**scaling factors Section 8.2 (6), page 43**  **Section 8.2 (7), page 45 Resolved** 

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and ( c): **In August 2001, EPA conducted a surveillance of the BCL RH WC program. In the re**  **port sent to DOE (EPA’s Technical and Regulatory Support Document for RH Waste Determinat**  **ion, February 2004, transmitted by EPA to DOE by Frank Marcinowski, March 26, 2004), EPA s**  **tated that “BC’s RH Program could be improved through more diligent acquisition and inte**  **gration of AK-based radionuclide information to determine isotopic distributions.”**  **EPA also questioned the representativeness of swipe samples collected that were later used as par**  **t of scaling factor/JN-1 isotopic mix development. EPA concluded that the “AK program da**  **ta assembly/compilation elements were not complete.” EPA concluded that while the radioa**  **ssay approach had merit, characterization activities performed to support the approach at the**  **time of the 2001 surveillance “were not technically adequate.”** 

**EPA’s current inspection identifies the following i ssues related to AK and radiological**  **characterization documentation completeness and ade quacy, many of which are related to issues**  **identified in our August 2001 surveillance: 23** 

Issue (a): **Isotopic ratio/composition information from two p rimary sources was used to**  **develop scaling factors (also the JN-1 Standard Iso topic Mix). The factors were derived**  **from a combination of swipe sample and modeling res ults, using input data to the model**  **(ORIGEN2.2) that originated in a memorandum from a 1 999 meeting. As an auditable**  **record, additional information and rationale suppor ting the approach is required both for the**  **isotopic distributions based on the swipe data and the recommended burn-up, enrichment,**  **and decay data from the 1991 memorandum. Documenta tion of the references and data**  **sources that were reviewed and evaluated during the 1999 meeting is necessary to support the**  **conclusions used by SRS-CCP. With regard to the sw ipe data, the sampling plan and**  **collection, the sample numbers, sampling results, a nd other relevant information must be**  **summarized to show that the sample data are suffici ently representative of the wastes within**  **Waste Stream SR-RL-BCLDP.001.**

Issue (c): **Through the course of the AK information acquisit ion and interpretation process,**  **the number of waste streams identified in JN-1 has changed over time. Specifically, the**  **current designation of Waste Stream SR-RL-BCLDP.001 stream was originally identified as**  **four separate waste streams. There is no informati on given to show these waste streams were**  **combined into a single stream.**

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and ( c) Resolution: **In response to Issues (a) and (c), SRS-CCP provided a formal resolution l**  **etter describing their approach, as well as References C510, C511, C513, and C520, three of whi**  **ch contain additional information pertaining to the 1999 memorandum. While the sourc**  **e of information for the parameter ranges in the 1999 memorandum was not cited in C511 other**  **than to cite general text references, C520 indicates that these ranges agree with the fuel lib**  **raries associated with ORIGEN 2.2, the sources of which are documented. Reference C513 provides a**  **dditional information concerning waste origin and distribution.** 

**Reference C510 states that while a sampling plan wa s not found, SRS-CCP interviewed the**  **individuals that performed the sampling and analysi s, and these individuals indicated that the**  **sampling was** authoritative **in nature. SRS-CCP representatives indicated that the samples were**  **selected to include the widest variety of surfaces within JN-1 to ensure that all possible**  **contaminated surfaces were tested. SRS-CCP did not provide additional information to**  **document that this approach was compliant with the WCPIP requirements for representativeness,**  **with the understanding that the WCPIP was not in pl ace at the time of sample collection.**  **Accordingly, SRS-CCP could not demonstrate represen tativeness of the 69 swipe samples**  **through a statistical analysis. It is evident from the available information that these wastes were**  **transferred and packaged without regard to the gene ration location within the JN-1 complex (i.e.,**  **wastes from different areas were packaged together) and thus potentially contaminating surfaces**  **throughout the JN-1 area. Accordingly, the JN-1 sa mple collection locations and number of**  **samples taken should result in a reasonable portray al of the potential contamination of the wastes**  **generated within the JN-1 complex.**

**EPA’s conclusions are based upon interviews with SR S-CCP personnel, as there is no sampling**  **plan or other documentation from the individuals wh o performed the sampling. To support both**  **SRS-CCP’s assessment and EPA’s inspection, EPA requ ired that SRS-CCP provide a** **24**

**memorandum documenting the sampling approach prepar ed by BCL staff familiar with the**  **swipe sampling at various JN-1 locations where RH d ebris waste was handled. EPA specifically**  **required that this memorandum address the sampling procedure and rationale that were followed,**  **with emphasis on the following:**

**(1) Guidance that was followed to develop and execute t**  **he sample collection, e.g., DOE Order, CBFO Procedure, or other guidance**  **(2) Sample protocols (reference the procedure(s) follow**  **ed) (3)**  **Reason for initial sample collection and the use of 69 samples to characterize the waste,**  **i.e., why 69 samples were considered sufficient (4)**  **Reason why the selected samples were considered rep resentative, i.e., selected from a**  **variety of surfaces that were typical of anticipate d contamination in all areas**  **(5) Indicate if the sampling was performed prior to app**  **roval of the WCPIP, if this is the case (6)**  **Specify timing of sampling and the selection of the 69 sample subset** 

**EPA determined that the lack of this information pr events EPA from independently verifying**  **that the data from the 69 swipe samples was represe ntative on the basis of the objective evidence**  **presented. Also, EPA considered it necessary to ha ve this information to support DOE’s**  **contention that 69 swipe samples are indeed represe ntative, as discussed in Section 8.2 (2).** 

**SRS-CCP prepared Reference C509, which documented w hy BCLDP personnel performed the**  **initial waste subdivisions, and why combining four different waste categories into a single**  **stream is appropriate and compliant with WCPIP and requirements.** 

**The CCP responded to EPA’s request in April 2008, p reparing a memorandum titled “Response**  **to EPA SRS RH Additional Information Request.” In response to EPA Items 1 and 2, the**  **memorandum stated the following:**

The sampling protocol used to collect the smears wa s the routine health physics survey procedure HP-OP-019, **‘** Radiation and Contamination Survey Techniques’ (AK source document number P751). This procedure, coupled with waste instructions, provided the documentation used by BC LDP to collect the samples. The BCLDP staff considered this procedure as equiva lent to the sampling plan at the time. Waste Instruction WI-956 (AK source docu ment number P707) is an example of a waste instruction from the 1999 time f rame.

**Review of these references indicates that while HO- OP-019 (P751) certainly contains**  **descriptions of smear survey protocols and other pr ocedures that could also be used in**  **characterization surveys, the document also states in Section 4.2 that “This procedure does not**  **apply to characterization surveys, nor is it intend ed to alter current or future characterization**  **surveys.” Reference P707 describes waste packaging protocols for pool filters and resins that are**  **outside of the current waste stream. The Memorandu m also relies heavily on expert judgment**  **and personnel expertise to support appropriate samp le collection. In response to EPA Item 3, the**  **Memorandum states that surveyed material, surveyed locations, and statistical analysis (Central** **25**

**Limit Theorum) indicate that 69 swipe samples are “ reasonable and adequate.” EPA agrees that**  **the number of samples collected should be sufficien t if the initial population selected for**  **sampling adequately captures the variability of the waste population as a whole. In response to**  **EPA Item 4, the Memorandum reiterates information o btained by EPA during the inspection that**  **samples were collected randomly from a variety of s urfaces to capture the range of potential**  **isotopic distributions that in the waste. The Memo randum, however, makes no statement**  **regarding collection of samples prior to approval o f the WCPIP (EPA Item 5).** 

**EPA recognizes that smear/swipe sampling was perfor med during the pre-2000 time period**  **(EPA Item 6), while EPA approved the WCPIP addressi ng RH waste characterization activities**  **in 2003. The WCPIP explicitly** requires **the preparation of a sampling and analysis plan wh en**  **sampling is performed (Section 4.8.1): “...A sampling plan shall be developed and documented**  **for each RH TRU waste stream....the burden of respons ibility for developing a technically sound**  **sampling plan rests with the TRU waste generator.” Since the smear samples were taken prior to**  **the sampling and analysis (S&A) plan requirement of the WCPIP, EPA understands that**  **compliance with all WCPIP requirements may not be p ossible for this waste stream.** 

**In the future, however, EPA expects that the CCP wi ll provide rigorous and detailed information**  **as part of the AK Record to document as much inform ation about waste sampling as possible**  **(such as that provided to resolve this EPA Finding) to meet the WCPIP-based sampling**  **requirements initially for EPA evaluation. When pr oposing another BCLDP RH waste stream**  **(e.g., BCLDP solids and soil/gravel) for EPA evalua tion and approval as a T1 change, the CCP**  **must provide rigorous and detailed sampling and ana lysis information when CCP cannot fulfill**  **the S&A plan requirement of the WCPIP. Based on th e information provided by CCP prior to,**  **during, and since the inspection, EPA concludes tha t the samples collected, together with Fuel**  **Type Scaling Factor comparisons (discussed in Secti on 8.2 of this report), results in a reasonable**  **description of the isotopic distribution sufficient to verify AK.** 

EPA Finding No. SRS-RH-AK-07-001F, Issues (a) and ( c) Status: **Based on the information examined, as discussed here and in Section 8.2 (7),**  **the EPA inspection team determined that the use of the 69 swipe sample data in the manner emplo**  **yed by SRS-CCP resulted in sufficient information to verify isotopic distributions presen**  **ted in the AK Summary and assumptions discussed later in Section 8.2 of this report. EPA**  **considers both Issues (a) and (c) to be closed.**

**(2) The identification of these wastes as defense-r elated, TRU versus HLW, low-level waste,**  **and SNF was examined and accepted.**

**CCP-AK-SRS-500 stated that the waste met the defini tion of defense waste, even though the vast**  **majority of radiological material managed in JN-1 w as non-defense-related. DOE agrees with**  **SRS-CCP’s justification as to the defense determina tion. DOE is solely responsible for the**  **determination. EPA does not evaluate the defense d etermination that DOE performs for TRU**  **waste destined for disposal at WIPP. The AK Summar y stated that the waste met the definition**  **of defense waste because defense-related naval reac tor material was managed in the complex,**  **and defense-related research and development activi ties took place in JN-1. The occurrence of**  **both activities would cause the defense and non-def ense material to be commingled, thus**  **imparting a defense determination to the waste. Th is is also documented in Reference C501.** **26**

**The AK Summary indicated that the waste did not con tain wastes derived from the separation or**  **reprocessing of constituent elements from reactor f uel, and the waste stream did not contain**  **irradiated fuel elements withdrawn from a reactor. SRS-CCP BCLDP representatives stated that**  **HLW is not included in this waste stream by definit ion. Similar to the LANL debris waste that**  **lacked an explicit SNF pedigree (see Air Docket No. A -98-49, II-A4-89), the RH debris waste**  **from BCLDP does not have an explicit SNF pedigree.**

**(3) Sufficiency of the AK summary and implementatio n of AK as required in Attachment A**  **of the WCPIP were evaluated and found to be adequat e upon revision of key documents.** 

**Attachment A of the WCPIP specifies that the follow ing be included in AK summaries:** 

• **Executive summary**

• **Waste stream identification summary**

• **AK data and information description**

• **Program information**

• **Waste stream information**

• **Qualification of AK information**

• **Container-specific information**

**Attachment A of the WCPIP mandates that the data co llection and analysis process should be**  **similar to the process that is used for CH wastes. Both the content of the AK summary and**  **sufficiency of AK implementation were assessed, and EPA determined that the AK Summary**  **adequately addressed the main required elements of the WCPIP. The EPA inspection team,**  **however, found discussion of additional separate wa ste streams within the text of the AK**  **summary, which implies that SRS-CCP may have been s eeking a broader scope of approval than**  **what EPA determined through interview of the AKEs. EPA focused only on Waste Stream**  **SR-RL-BCLDP.001 and limits its evaluation to that w aste stream. The EPA inspection team**  **also found the discussion in CCP-AK-SRS-500 concern ing the “standard” versus “non-standard”**  **radiological mixes and differing characterization p rocesses confusing. The AKE indicated that**  **this waste stream was only characterized using the JN-1 Standard Isotopic Mix and no other**  **sampling or analysis approach was apparently used t o characterize waste outside of this stream.**  **The text of CCP-AK-SRS-500 did not include informat ion pertaining to the general radiological**  **content of materials managed in the JN-1 HCL, inclu ding the number of experiments associated**  **with LWR and other reactors or related isotopic inf ormation. While the AKE indicated upon**  **interview that only material originating from withi n JN-1 HCL was present in waste, AK data**  **provided as references and in the CRR were confusin g, because it was unclear how radiological**  **data from the JN-2, JN-3, and JN-4 areas pertain to JN-1. This was discussed with SRS-CCP**  **personnel during the inspection and EPA included th is issue as a finding on the EPA Inspection**  **Issue Tracking Form that was discussed throughout t his report (see Attachment A of this report**  **for a copy of this form). The aspects of the findi ng that pertain to the content of the AK**  **Summary are presented below:**

EPA Finding No. SRS-RH-AK-07-001F, Issue (b): **EPA’s current inspection identifies the following issues related to AK and radiological cha**  **racterization documentation completeness and adequacy, many of which are related to issues i**  **dentified in our August 2001 surveillance: 27** 

**CCP-AK-SRS-500 must be revised to address the follo wing:** 

• **Only describe the SRS waste stream of 87 drum liner s subject to this inspection.** 

• **The document states that there are wastes in this s tream that exhibit both “standard” and**  **“non-standard” isotopic distributions, and that non -standard waste will undergo separate**  **sampling and analysis. However, the AKE indicated that only “standard” isotopic mix**  **wastes are included in the stream, and there are no wastes that underwent the alternative**  **sampling and analysis approach discussed in the tex t.** 

• **Include a thorough presentation of general radiolog ical characteristics of wastes.**  **Information such as types of radionuclides handled in JN-1 in the various cells/areas,**  **origin of radionuclides (e.g., LWR), outliers, and any other information necessary to**  **provide a general overview of the radionuclides han dled through the course of JN-1**  **operations is necessary.**

EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Resolu tion: **SRS-CCP revised CCP-AK-SRS-500, noting that the number of drum line**  **rs within the most recent version was correctly reduced to 87. SRS-CCP removed the 88**  **th drum liner from consideration as it did not**  **meet the definition of TRU waste and, hence, not el igible for WIPP disposal. Also, while**  **additional process information and the CCP radiolog ical characterization approach were included**  **in Revision 1 of CCP-AK-SRS-500, the radiological d ata cited in the EPA finding was included**  **in Revision 2 of CCP-AK-SRS-501. Therefore, the ra diological characteristics of waste are**  **adequately defined in the combination of the inform ation presented in the revised CCP-AK-SRS**  **500 and CCP-AK-SRS-501 reports, as well as supporti ng references.** 

EPA Finding No. SRS-RH-AK-07-001F, Issue (b) Status : **Based on the information examined, the EPA inspection team determined that t**  **he AK Summary had been adequately revised to address the above issues. EPA considers**  **this aspect of the finding to be closed.**

**(4) Data traceability was examined and found to be adequate upon incorporation of**  **additional information.**

**Data traceability was assessed to understand the hi erarchy of information that was ultimately**  **used by AK personnel to identify the physical and r adiological parameters associated with this**  **waste stream. SRS-CCP-BCLDP personnel provided the following information pertaining to**  **data traceability:**

• **Waste Packaging Records for Liners BC0127 (Pressure Wash Filters), BC0075, and**  **BC003 (Liner in Canister)**

• **Certification Paperwork for Liners BC0127 (Pressure Wash Filters), BC0075, and BC003**  **(Liner in Canister)**

• **HP Survey Report for Liners BC0127 (Pressure Wash F ilters), BC0075, and BC003**  **(Liner in Canister) 28** 

• **CCP-AK-SRS-501, Appendix 3, Waste Container Dose to Curie Conversion Records**  **(All 87 Drum Liners)**

• **Calculation Packages P729, P7353, and P737**

**This waste stream did not have individual records p ertaining to isotopic characteristics of**  **individual containers (i.e., data that associated t he 69 swipe samples with specific containers or**  **campaigns were not available, and individual drum d ata except for drum loading travelers were**  **not available). The AKE stated that the liners wer e not typically packaged in the same room or**  **cell where the wastes were generated, so there coul d be no correlation between wastes and their**  **generation point. However, VE records document the origin of individual waste items within the**  **liners and shows that multiple areas may have contr ibuted to the waste in an individual drum**  **liner. Typically for CH TRU wastes, EPA evaluates traceability of radiological measurements of**  **waste containers (drums) during the on-site inspect ion. In the case of this RH waste stream, the**  **measurements used to support the WC are historical, which complicates the data traceability**  **evaluation. Assessing data traceability is necessa ry to understand the origin and hierarchy of**  **radionuclide and physical data associated with each canister. See Sections 8.1 (1) and 8.1 (2),**  **above, regarding deficiencies with respect to radio nuclide data traceability and supportability.** 

**(5) Sufficiency of AK support documents and related document tracking was evaluated and**  **was found to be adequate.**

**A list of AK source document references was prepare d using unique identifiers for the different**  **document types following the format used by SRS-CCP for CH wastes. The listing is based on**  **CCP-TP-005 Revision 18, Attachment 4. The listing was complete and was easy to understand,**  **because it followed the same format used for CH was te streams. Several AK support documents**  **were referenced in the text and these documents add ress the specific element or issue with the**  **AK summary, although applicability does vary. EPA only examines support documentation**  **specific to the technical element referenced in the AK summary that caused that support**  **reference to be selected for examination.**

**(6) Interpretation of WCPIP was evaluated with respect**  **to contents of the Certification Plan, the CTP and the proposed characterization process a**  **nd was found to be adequate.**

**EPA’s RH WCPIP framework approval letter dated Marc h 26, 2004, indicated that sites must**  **generate a Certification Plan that explains how RH waste characterization will take place at each**  **site, as well as a CTP. Based on the previous RH i nspection experience, EPA determined that**  **combining the Certification Plan and CTP in a singl e document that described the proposed**  **characterization process would satisfy the EPA requ irements. In this instance, however, EPA**  **observed that language within the CTP is sometimes confusing, as indicated in Item 7 below.** 

**(7) Content and technical adequacy of the CTP was e valuated and found to be adequate.** 

**The WCPIP requires a description of the following i tems to be included in the CTP:** 

• **The waste stream or waste stream lots to which the plan applies** **29**

• **The confirmatory testing proposed, including the pe rcentage of waste containers that will**  **be subject to confirmatory testing**

• **The WC DQOs and quality assurance objectives (QAOs) that will be satisfied with the**  **data being qualified**

• **The DQOs and QAOs that will not be confirmed with t he data being qualified and an**  **explanation of how compliance with those DQOs and Q AOs will be demonstrated** 

• **How the tested subpopulation is representative of t he waste stream or waste stream lot** 

**The required bullets listed above are addressed in the CTP. In the case of this waste stream, the**  **CTP also includes a discussion pertaining to AK acc uracy and related DQOs. Because this**  **specific waste stream deals solely with AK-based WC , an evaluation of AK accuracy is not**  **applicable (other than to document this statement i n an AK accuracy memorandum and within**  **the CTP). Also, EPA has noted that the use of the term**  confirmation **is sometimes confusing in that EPA regards confirmation to mean actual radiol**  **ogical measurement data or estimation of physical contents of a waste container to confirm A**  **K information, but CCP has sometimes used the term in a broader sense when verification activ**  **ities take place. EPA understands that the form and substance of the CTP is designed to meet t**  **he requirements stated in the WCPIP, but care should be exercised in future RH site document**  **ations with regard to the use of the term** confirmation

**. (8) Content and technical adequacy of the CRR was e**  **valuated and the process was found to be adequate as using example data provided for this**  **inspection.**

**The EPA inspection team evaluated the CRR against r equirements in CCP-TP-506, Revision 1,**  **for Waste Stream SR-RL-BCLDP.001 to evaluate if thi s report reflected the requirements of**  **CCP-TP-506, and to ensure that the CRR addressed re quirement elements as specified in the**  **WCPIP, including the following:**

• **Specification of applicable site and waste stream**

• **A listing of each DQO**

• **Data from the AK record that addresses each DQO**

• **AK source document references that support/provide the data** 

• **A listing of AK record DRs relevant to each DQO, if any** 

• **Documentation, including specific references, of ho w the AK data for each DQO were**  **qualified, such as batch data reports, corroborativ e data, proceedings of a peer review,** 
**etc.**

• **Real Time Radiography (RTR) and/or VE summary to do cument that liquids greater than**  **1% are absent from the waste and to confirm AK conc erning the physical properties of**  **the waste**

• **A summary presentation of radiological measurement data used to meet the DQOs and to**  **confirm AK 30** 

• **A complete AK summary**

• **A complete listing of all container identification numbers used to generate the Waste**  **Stream Profile Form (WSPF), cross-referenced to eac h BDR** 

• **A listing of AK discrepancies generated by an AK qu alification process and the**  **corresponding resolutions**

• **Signature of the Site Project Manager (SPM)**

**The example CRR that the EPA inspection team examin ed included all of the above WCPIP**  **requirements. As had been observed previously for the RH WC programs at INL and Argonne**  **National Laboratory-East (ANLE) (see Docket Nos. A-98 -49, II-A4-72 and A-98-49, II-A4-73,**  **respectively), the CRR DQO worksheet (Attachment 3 of CCP-TP-506) for this RH waste stream**  **did not include a listing of the 10 WIPP-tracked ra dionuclides as part of the DQO assessment**  **process. These radionuclides need to be specified, quantified, and assessed as part of the CRR.**  **In the past, site representatives declined to speci fically address these because it is not required by**  **the WCPIP. However, EPA requires information for t he 10 WIPP-tracked radionuclides and the**  **CRR generated at other CCP RH TRU sites must includ e the ten radionuclides. The reason for**  **this is that for the WIPP Performance Assessment pe rformed in conjunction with the WIPP**  **Repository Recertification every 5 years, identific ation and quantification of the 10 WIPP**  **tracked radionuclides is essential.**

**Radiological characterization BDRs are not prepared , because the characterization is performed**  **based solely on AK. However, SRS-CCP documents the compliance of each container with**  **DQOs and other SPM approvals (signatures) on Attach ments 1 and 2 of CCP-TP-506, and the**  **results of this analysis are rolled up into Attachm ents 3 and 4 of CCP-TP-506. The EPA**  **inspection team usually examines these individual a ttachments to ensure that complete, drum**  **specific documentation is kept for each container t hroughout the process, and to ensure that this**  **information is adequately “rolled up.” During this inspection, only the single example draft**  **attachment was available. SRS-CCP personnel stated that data will be manually downloaded**  **from CCP-AK-SRS-501 into a WWIS controlled spreadsh eet. When such data are entered**  **manually, DOE needs to provide to EPA for review a copy of the WWIS spreadsheet showing**  **manual data entries.**

**(9) Use of a Correlation and Surrogate Summary Form was evaluated and was found to be**  **adequate.**

**Completion of a Correlation and Surrogate Summary F orm is required when AK information**  **from a related CH waste stream is used in the RH WC . The CCP AKE stated that to date, no CH**  **surrogate container has been identified pertinent t o this waste stream** 

**. (10) Personnel training was evaluated and found to**  **be adequate.**

**Training records for Sherri Nance and Rob Tayloe we re examined. Ms. Nance’s training was**  **evaluated with respect to training to the RH TRU WC PIP, non-conformance and corrective**  **action processes, the AK procedure presented in Att achment A of the WCPIP, site-specific**  **training relative to the contents of the subject wa ste stream(s), and determination of radiological** **31**

**contents of individual drums. The Qualification Ca rd examined demonstrated training in each**  **area except for non-conformances (which should be n ot applicable for this waste stream) and the**  **determination of the radiological contents of each drum. Where detailed radiological analysis**  **and expertise are required, Messrs. Jene Vance and Rob Tayloe performed those tasks. The**  **expertise of Messrs. Vance and Tayloe was examined and Mr. Tayloe’s resume was reviewed,**  **since he was the CCP technical expert for radiologi cal characterization. Although Mr. Tayloe**  **did not show direct training with respect to this a rea, his resume showed considerable expertise**  **suitable to demonstrating proficiency. In summary, the evaluated AKE and the radiological**  **Subject Matter Expert demonstrated the necessary le vel of knowledge in the area of radiological**  **assessment through on-the-job training.**

**(11) Discrepancy Resolution (DR) Forms were examine d and found to be adequate.** 

**Because measurement data were not collected for thi s waste stream and all characterization is**  **based on AK, Non Conformance Reports (NCRs) were not created. Instead, issues identified**  **were AK-AK in nature, so DR forms were created. DR numbers DR001 through DR0010 were**  **provided within the CRR. The forms provided detail AK-AK discrepancies dealing with**  **radiological data in JN-4, transfer pool constructi on dates, WMP percentage recalculation,**  **evaporation of JN-1 pool water, analytical data per taining to the JN-1 pool (not included in this**  **waste stream), Resource Conservation and Recovery A ct (RCRA) code assignment, waste**  **generation parameter discrepancies, and JN-1 pool w ater prefilter radiological data (not included**  **in this waste stream). Most of these documents wer e prepared prior to the current SRS-CCP**  **documentation process, and the documents adequately address the DR process. When SRS-CCP**  **addresses items 1 and 3 above, discrepant data may be identified that require resolution or at**  **least documentation. When this occurs, EPA expects that all discrepancies identified will be**  **documented on DR forms with the appropriate support ing documents, and that this information**  **(if generated) will be placed in the AK record and provided to EPA for review.** 

**(12) A WSPF was examined and was found to be adequa te.** 

**An example WSPF was examined for Waste Stream SR-RL -BCLDP.001. The form included the**  **required items as presented in the WCPIP, Attachmen t 4; the CRR and RH AK summary are also**  **required for submission to CBFO to allow assessment of the WSPF. EPA understands that this**  **form was abbreviated, because it was provided for i nspection purposes only, and expects that the**  **completed form will include more AK data, checklist s (as applicable), etc., to better present the**  **required information. EPA expects to receive the c ompleted WSPF for review when available.** 

**(13) AK accuracy was assessed for applicability and was adequately addressed in the context**  **of this waste stream.**

**The WCPIP requires determination of AK Accuracy in three areas: reassignment of the waste to**  **a different SCG; reassignment of the waste to a dif ferent waste stream; and stream-specific**  **assessment of radiological parameter accuracy. In the case of Waste Stream SR-RL**  **BCLDP.001, all characterization was based on AK alo ne, so an accuracy determination based on**  **measurement versus AK comparisons cannot be perform ed. SRS-CCP included a discussion of**  **AK Accuracy in the CTP and an AK Accuracy Memorandu m. In this document, SRS-CCP cites** **32**

**comparisons of the modeling/sampling and AK data wi th respect to TRU waste determination**  **qualification. CCP-AK-SRS-502 states that TRU wast e determination qualification is**  **accomplished through comparison of AK and drum line r (also AK) measurement results, while**  **activity determination qualification was accomplish ed through AK-based modeling and AK**  **sampling results. CCP-AK-SRS-502 also states that AK Accuracy DQOs for residual liquid and**  **physical form are demonstrated through packaging re cords. While the comparisons do show that**  **AK data are in agreement in the cited examples, the information does not address AK Accuracy,**  **which addresses the comparison of confirmatory meas urement data and the AK record.**  **Therefore, EPA concludes that AK Accuracy cannot be assigned for this waste stream, because**  **confirmatory sampling and analysis information were not obtained and, therefore, there is no**  **information on which to base an assessment of AK Ac curacy.** 

**(14) The use of load management for this waste stre am was assessed and was determined to**  **be not applicable at this time.**

**The possibility that containers have TRU concentrat ions less than 100 nCi/g was evaluated.**  **None of the drum liners were reported to have TRU co ncentrations less than 100 nCi/g. The**  **SRS-CCP SPM stated that this waste stream will not undergo load management, so approval of a**  **load management by EPA is not requested. Since the se drum liners are not likely to be opened**  **for repackaging or adding other TRU waste, EPA expe cts load management not to occur. In a**  **highly unlikely event SRS-CCP considers load manage ment, compliance with Appendix E of the**  **TRU Waste Acceptance Criteria (WAC) is necessary.**

8.2 Radiological Characterization

**EPA evaluated the method by which the required radi ological constituents for each waste**  **container were determined. The nature of RH TRU wa stes presents some difficulty with respect**  **to obtaining meaningful measurement data, as is rou tinely done with CH TRU. Apart from the**  **obvious personnel concerns associated with working in external radiation fields in excess of**  **200 millirem per hour (mrem/hr), RH TRU waste conta iners typically contain concentrations of**  **energetic photon emitters, i.e., 137**  **Cs and/or 60**  **Co that prevent a meaningful measurement-based isotopic determination. Accordingly, RH radiologic**  **al characterization relies heavily on alternate methods such as the development of scaling factors**  **that can correlate an easily measured parameter like external exposure (dose) rate with i**  **sotopic distributions for target radionuclides.**

Overview of SRS Radiological Characterization Progr am

**SRS-CCP’s approach to radiological characterization is generally consistent with the**  **requirements and guidance provided in the WCPIP. T he overall approach to radiological**  **characterization SRS-CCP used for the BCLDP RH wast e has several elements in common with**  **the RH characterization approach EPA observed in th e LANL-CCP RH program during EPA**  **inspection No. EPA-LANL-CCP-RH-5.07-8 (see Docket No. A-98-49, II-A**  **4-89). During this RH inspection, the EPA inspection team evaluated th**  **e conceptual bases of the characterization approach, including:** **33**

• **Evaluation of radiochemical analyses of 69 swipe or smear samples taken in the JN-1**  **facility to support the development of scaling fact ors using ORIGEN2.2 results** 

• **Development of a DTC correlation as a function of w aste density using Microshield®**  **based on each waste liner’s measured external expos ure (dose) rate, assuming the main**  **contributor to the external exposure was 137**  **Cs**

• **Derivation of radionuclide scaling factors for the WIPP-tracked radionuclides using**  **ORIGEN2.2 based on the attributes of LWR fuels**

**With the exception of the use of radionuclide data from the swipe samples, these techniques have**  **been evaluated in detail during previous RH inspect ions. For a thorough evaluation of the**  **conceptual basis and application of DTC and the dev elopment and application of scaling factors,**  **the reader is directed to the baseline inspection r eports for these RH inspections (see Docket Nos.**  **A-98-49, II-A4-72; A-98-49, II-A4-73; and A-98-49, II-A4-89). These characterization methods**  **used for the BCLDP SRS RH wastes were evaluated in terms of the technical adequacy of the**  **approach as supported by the SRS-CCP WC program’s d ocuments, procedures, and controls, and**  **the knowledge and understanding of the personnel in volved in the RH WC program.** 

Technical Evaluation

**The EPA inspection team evaluated the following asp ects:** 

**(1) The technical adequacy of the radiochemical sw ipe data was evaluated and was found to**  **be adequate.**

**CCP-SSR personnel stated that between 1996 and 1999 hundreds of swipe samples were taken**  **from various areas within the JN-1 Facility as part of the site’s routine contamination control**  **program. These samples were collected periodically , depending on the conditions or activities**  **within the facility. Some of the swipe samples wer e also used to identify the radionuclide**  **content of the subject waste stream and thee swipe sample assay results were used to support the**  **derivation of radionuclide scaling factors. During these surveys, surfaces were identified for the**  **collection of one or more swipe samples of floors, work surfaces, equipment, waste containers**  **and tools that were subsequently submitted for radi ochemical analysis. Table 4-2 of**  **CCP-AK-SRS-501 lists the types of surfaces within J N-1 that were swiped. This process**  **produced a total of 47 of swipes and 22 additional samples from high-efficiency particulate air**  **filters from the ventilation system servicing areas within the JN-1 HCL for a total of 69 samples**  **that were submitted for a suite of radiochemical an alyses. The analyses consisted of: alpha**  **spectrometry for isotopes of americium, uranium, pl utonium and thorium**  **10 ; gamma spectrometry**  **for specific isotopes of cobalt, cesium, europium a nd antimony; and liquid scintillation counting**  **for the beta-emitting 90**  **Sr.**

**The EPA inspection team did not observe objective e vidence documenting the purpose for which**  **the swipes were taken, although SRS-CCP personnel s tated they were collected to support the** 

**10 SRS-CCP records do not indicate the specific metho**  **dology used to quantify 244**  **Cm and 237**  **Np although alpha spectrometry is the usual analytical approach used**  **to identify and quantify these radionuclides. 34** 

**development of radionuclide scaling factors, as sta ted in CCP-AK-SRS-501. SRS-CCP records**  **indicate that while many of the 10 WIPP-tracked rad ionuclides were among the list of target**  **radionuclides some were not, specifically 241**  **Pu 11**  **and 242**  **Pu. SRS-CCP personnel stated that the radioanalytical values in CCP-AK-SRS-501 represent**  **all the available values, and that it is possible that all 69 swipe samples were analyzed fo**  **r the full list of target radionuclides but not all samples showed measurable values for these radi**  **onuclides. Accordingly, although 69 swipe samples were analyzed for**  **238 Pu,**  **60 Co and**  **90 Sr, the analytical results showed 69 measurable**  **values for 238**  **Pu, 61 measurable values for 60**  **Co and 13 measurable values for 90**  **Sr. Analytical results that were not detected, i.e., below the ass**  **ay system’s lower limit of detection (LLD) 12**  **for a specific radionuclide, are not available. The nu**  **mbers of usable values based on these analyses are shown in Table 4, below. Because the EPA inspe**  **ction team was unable to determine how many swipe samples were taken in JN-1, it is not po**  **ssible to establish what fraction of the total sampling effort within the JN-1 facility the 69 sam**  **ples represent, which has bearing on the samples’ representativeness, as discussed in Sectio**  **ns 8.1 (1) and 8.2 (2), below. Based on the available information the EPA inspection team accep**  **ted that the 69 analytical results that are available constitute all useable radionuclide value**  **s discussed in Section 8.1 above and item (2), below.** 

Table 4. Summary of the Reported Radionuclides in the 69 Smear Samples

Radionuclide Number of Samples Analyzed Number of Values

Above MDA Number of Values

Below MDA

**241 Am 69 69 0** 

**244 Cm 69 69 0** 

**238 Pu 69 69 0** 

**239 Pu/**  **240 Pu 69 69 0** 

**60 Co 69 61 8** 

**154 Eu 69 54 15** 

**134 Cs 69 49 20** 

**233 U/**  **234** **U* 29 24 5**

**90 Sr 13 13 0** 

**238** **U* 29 13 16**

**235 U/**  **236 U 29 4 25** 

**237 Np 24 4 20** 

**230 Th 24 12 12** 

**125 Sb 69 8 61**  *** Two anomalous uranium results were removed from population** 
**The analyses were conducted by a commercial laborat ory (Data Chem) and by BMI. The criteria**  **for deciding where the samples were analyzed are no t clear but available information suggests**  **that BMI performed all of the gamma spectrometry an alyses, Data Chem performed the early** 

**11 241**  **Pu is not one of the 10 WIPP-tracked radionuclides but it may be useful in developing radionuclide sca**  **ling factors.** 

**12 Although they are technical different, in this con**  **text the term** LLD **is taken to be synonymous with Minimum Detectable Activity (MDA).** **35**

**alpha spectrometry analyses and BMI performed the l ater alpha spectrometry analyses. No**  **formal evaluation of the Data Chem and BMI radioana lytical data provided by SRS-CCP was**  **deemed unnecessary. Both laboratories provided rep ort sheets that were reviewed during the**  **inspection and examples of these are included in at tachments to CCP-AK-SRS-501. The EPA**  **inspection team reviewed a sampling of these data s heets for gamma spectrometry, alpha**  **spectrometry and isotopic uranium from BMI and all were adequate. The swipe data are**  **technically adequate and sufficiently documented to support the development of radionuclide**  **scaling factors.**

**(2) Representativeness of Radiochemical Swipe Dat a** 

**The degree to which the 69 swipe samples that were subjected to radiochemical analysis are**  **representative of the wastes that were handled with in the JN-1 HCL is of key importance [see**  **Section 8.1, (1), above]. Specifically, the contam ination on the swipes must represent the types**  **and characteristics of fuel rods that were handled in JN-1 to technically support the scaling factor**  **development presented in CCP-AK-SRS-501. As discus sed above, apart from the analytical**  **results, initially SRS-CCP did not produce addition al objective evidence to support the design or**  **intent of the sample collection and analysis proces s. The most important piece of documentation**  **would be a sampling plan, which would ideally discu ss the measures taken to ensure that the**  **samples collected were indeed representative of the materials used within the sampled area.**  **Similarly, detailed information on the types and ch aracteristics of fuel rods that were handled in**  **the JN-1 was not available. Without this informati on, EPA cannot confirm that the**  **areas/materials that were swiped are representative of the fuels that were handled in JN-1 on the**  **basis of documentation. Accordingly, the EPA inspe ction team concluded during the July 2007**  **inspection, that SRS-CCP’s contention that the swip es are representative was not adequately**  **supported. This was discussed with SRS-CCP personn el during the inspection and EPA included**  **this in the EPA finding discussed throughout this r eport.** 

**In the absence of documentation regarding sample co llection, the EPA inspection team focused**  **on an empirical determination to address the issue of representativeness. Because exact**  **information regarding the contribution of the fuels handled within JN-1 was unknown, the**  **average scaling factors for all fuel types, i.e., L WR, highly enriched uranium (HEU) and**  **thorium, were plotted against the scaling factors d erived from the swipe data and the application**  **of ORIGEN2.2. The comparison is shown in Figure 5-1 , of CCP-AK-SRS-501 and is**  **reproduced in this report as Figure 2, below. This plot indicates good agreement between the**  **results of the swipe analyses and the characteristi cs of LWR fuel for the majority of the**  **radionuclides, with the exception of 230**  **Th, the uranium isotopes and 154**  **Eu. SRS-CCP personnel stated that these differences can be explained base**  **d on: a lack of equivalent data for 230**  **Th; the unexpected processing of unirradiated fuel which wo**  **uld skew the uranium values; and, simple radioactive decay of**  **154 Eu due to its shorter physical half-life. These is**  **sues are discussed in detail in CCP-AK-SRS-501, Revision 2.** **36**

Figure 2. Comparison of Scaling Factors Representa tive of Different Fuel Types Against Average Smear Sample Scaling Factors

**Upon examination during and after the inspection, t he EPA inspection team personnel agreed**  **that the empirical demonstration shown in Figure 2, below, had considerable technical merit.**  **EPA’s acceptance of SRS-CCP’s assertion of represen tativeness is based on the technical merit**  **of the empirical demonstration, as discussed in the preceding paragraph. EPA inspection team**  **personnel revisited this issue following revision o f CCP-AK-SRS-501 and the other documents**  **discussed in Section 8.1 (1), above, during the Jul y and December 2007 meetings. The revised**  **documents provide additional details relative to th e representativeness of the swipe samples.**  **However, the lack of specific information regarding the design or intent of sample collection is a**  **weakness. In the future, when sample collection pl ays as important a role in a site’s RH WC**  **program as it does for this waste stream, EPA will require that the site provide a sampling plan**  **as required as part of EPA’s site procedures review and approval prior to the baseline inspection.**  **Based on the strength of the empirical demonstratio n supported by the revised documents, EPA**  **agrees that there is sufficient support for SRS-CCP ’s contention that the swipes are**  **representative of the attributes of LWR. Also, as discussed in Section 8.1 above, based on the**  **additional documentation provided by CCP, EPA concu rs that the 69 swipe samples are**  **representative of the different fuel types handled in the hot cell.**  **1.0E-09 1.0E-08**  **1.0E-07 1.0E-06**  **1.0E-05 1.0E-04**  **1.0E-03 1.0E-02**  **1.0E-01 1.0E+00** 

**TH230 U233** 

**/4 U23**  **5/6 U238**  **P**

**U 238** 

**P U239/4**  **0 AM241**  **CM**

**24 4**  **SR 90 SB1** 

**2 5**  **CS134 E** 

**U 154** Scaling Factor **Thorium**

**LWR**
**HEU Sample Data** **37**

**(3) The development of radionuclide scaling factor was evaluated and found to be technically**  **adequate.**

**In the absence of specific fuel irradiation data, i nformation regarding the fuels materials’**  **235 U**  **content, burn-up and decay was selected based on th e assumption that the majority of the TRU**  **materials within the JN-1 facility were LWR fuels. Ranges for these parameters were developed**  **in 1999 [see Section 8.1 (1)] as input for 1000 ORI GEN2.2 calculations, the results of which**  **were used to derive radionuclide scaling factors fo r**  **241 Am,**  **238 Pu,**  **239 Pu,**  **240 Pu,**  **241 Pu,**  **242 Pu,**  **234 U,** 
**235 U,**  **238 U and**  **60 Co plus the fission product**  **154 Eu. These scaling factors were compared with**  **radionuclide-specific data generated by the radioch emical analysis of 69 swipe samples that were**  **collected from locations inside the JN-1 facility, as discussed in the previous section. The**  **scaling factor for 233**  **U was developed exclusively on the basis of the 234**  **U results of the swipe sample analyses, as discussed below. The determina**  **tion of 154**  **Eu and 60**  **Co was necessary to account for their potential contribution to the mea**  **sured dose rate and to identify all radionuclides that contribute to 95% of each liner’s radiological**  **hazard 13** 

**. The EPA inspection team evaluated the following asp**  **ects:**

• **Activity values that are used are derived from mode ling and statistical metrics that**  **support their use, and the statistical metrics incl ude mean and standard deviation values**  **for each measured radionuclide.**

• **The appropriateness of the choice of physical const ants and radionuclide-specific**  **attributes (specific activity, physical half-life, decay heat, neutron cross-sections, photon**  **transition probabilities, etc.) and the technical c orrectness of the values assigned to each**  **attribute.**

• **Isotopic activity values are correlated to each dru m liner’s major radionuclide content(s)**  **responsible for the measured external dose rate, i. e.,**  **137 Cs and**  **60 Co.** 

• **The calculated results used to develop the factors and convert the measured external dose**  **rates to radionuclide activity levels.**

• **Calculations supporting the scaling factors were pe rformed using appropriate shielding**  **analysis techniques, i.e., Microshield ®** 

**. Regarding the second bullet, above, Revision 1 of C**  **CP-AK-SRS-501 did not cite the source of the specific activity and physical half-life values**  **, although SRS-CCP personnel stated that these values were taken from the CH TRAMPAC. The lack of**  **this reference was included in EPA Finding No. SRS-RH-AK-07-001F, which is discussed in**  **Section 8.2 (7), below. All references were appropriately cited in Revision 2 of CCP-AK-SR**  **S-501 that the EPA inspection team reviewed during the December 2007 meeting, which cl**  **osed this part of the finding.**

**The purpose of a radionuclide scaling factor is to provide a technically sound method of deriving**  **values for the 10 WIPP-tracked radionuclides within each container based on the container’s** 

**13 Although the determination of a waste container’s**  **radiological hazard is not an EPA requirement, this information may be useful in understanding other as**  **pect of a container’s radiological characterization**

**. 38** 

**measured external dose rate. ORIGEN2.2 was used to derive scaling factors for all of the**  **reportable radionuclides based on the ranges of the three parameters listed below as input:** 

• **235 U enrichment – 2.0 to 4.0 (weight percent)** 

• **Burn-up – 15k through 45k**

• **Decay (years post-irradiation to 2002) – 13 through 30** 

**These ranges were based on the assumption that the materials processed in the JN-1 HCL were**  **predominantly LWR fuels, which is discussed earlier in this report. With the exception of**  **233 U,**  **the scaling factor for each radionuclide was determ ined by taking the arithmetic mean of 1000**  **ORIGEN2.2 runs. The treatment of 233**  **U is addressed below. The scaling factors are mult iplied**  **by the 137**  **Cs concentration, which is derived based on the mea sured dose rate of each drum and**  **the DTC technique discussed below. The mass (gram) quantities of the actinides were extracted**  **from the ORIGEN2.2 output results along with the ac tivity (curie) quantities of the fission**  **products. Mass and activity values can be converte d interchangeably using the specific activity**  **values provided in the Contact-Handled Transuranic Waste Authorized Methods for Payload**  **Control (CH-TRAMPAC). The average scaling factors representing the total fuel pin population**  **were calculated by taking the ratios of the average curies of each radionuclide to the average**  **curies of 137**  **Cs in a metric ton of fuel. These averages are the actual scaling factors used to**  **derive the quantities and distribution of the radio nuclides for all 87 drum liners in this population**  **of BCLDP RH wastes. The standard deviation for eac h radionuclide was used to calculate the**  **relative standard error associated with its variati on in the fuel compositions. CCP-AK-SRS-501,**  **Table 6-1, lists the scaling factors derived in thi s manner for each of the radionuclides that was**  **used to characterize the 87 drum liners. This tabl e is reproduced as Table 5, below, and lists the**  **scaling factors in units of curies of each radionuc lide per curie of**  **137 Cs (Ci/Ci**  **137 Cs).** 

**The scaling factor for 233**  **U was developed from the geometric mean of the swip e sample data**  **discussed in a previous section. Because the analy tical technique of alpha spectrometry is unable**  **to resolve the peaks of 233**  **U and 234**  **U, the 233**  **U activity would be reported as 234**  **U, a value that includes both**  **233 U and**  **234 U. To provide an upper estimate of both radionucli**  **des, the scaling factor derived for**  **234 U based on the swipe sample data is used for**  **233 U also.** **39** Table 5. Radionuclide Scaling Factors

Radionuclide Scaling Factor, Ci/Ci 137 Cs
**U-233 5.12E-05**
**U-234 2.59E-05**
**U-235 3.58E-07**
**U-238 5.89E-06**
**Pu-238 3.41E-02**
**Pu-239 5.83E-03**
**Pu-240 9.48E-03**
**Pu-241 6.87E-01**
**Pu-242 3.01E-05**
**Am-241 5.00E-02**
**Cm-244 1.76E-02**
**Co-60 2.27E-02**

**Sr-90** 6.77E-01
**Y-90 6.77E-01**
**Cs-137 1.00E+00**
**Ba-137m 9.46E-01**

**(4) The DTC Correlation was evaluated and found to be technically adequate.** 

**The DTC correlation was based on the following assu mptions:** 

• **The waste density was uniform within the liner.**

• **All liners were nearly completely filled with waste material.** 

• **An iron matrix is the most representative, i.e., ph oton attenuation is primarily a function**  **of the matrix density rather than composition.**

• **The vast majority of the measured external exposure rate consists of**  **137 Cs and/or**  **60 Co.** 

**Using Microshield ®**  **, SRS-CCP developed a DTC correlation for the drum liner configuration**  **illustrated in Figure 1 and expressed it in terms o f Roentgen per hour per curie of**  **137 Cs (R/hr/Ci**  **of 137**  **Cs). This was based in large part on the shielding calculations for a BCLDP liner filled**  **with RH TRU waste assuming a 1curie source of eithe r**  **137 Cs or**  **60 Co uniformly distributed about**  **the waste. Figure 3, below, shows the results of t hese calculations and the polynomial fit to the**  **calculated data for 137**  **Cs and 60**  **Co as a function of waste density. This plot is a composite of**  **Figures 3 and 4 from SRS-RH-02, Revision 1, and is also presented in CCP-AK-SRS-501 as**  **Figure 7-3. 40** 

Figure 3. DTC Correlations as a Function of Waste Density at a Distance of 1 meter Centered on a RH TRU Drum Liner

**The DTC calculations were performed using an EXCEL spreadsheet using the container’s gross**  **weight, the estimated fill percentages, and the two dose**  **rate measurements as input. An example of the DTC spreadsheet is shown in Figure 4 for an**  **actual BCLDP RH-TRU waste drum liner, using measured dose rates and container weights fro**  **m 2002 and the more recently developed radionuclide scaling factors described above. The**  **uncertainties shown in the spreadsheet are associated with this drum liner and indicate the re**  **lative magnitude of the overall uncertainties in each of the radionuclide quantities listed on the s**  **preadsheet.** y = 20.615x 2 - 107.2x + 197.8
R 2 = 0.9995 y = 57.41x 2 - 349.19x + 794.6

R 2 = 0.9999

0 100 200 300 400 500 600 700 800

0 0.5 1 1.5 2 2.5
Waste Density in Grams/cm 3 Dose Rate, R/hr

One Meter Cs-137 Dose Rate, mR/hr/Ci One Meter Co-60 Dose Rate, mR/hr/Ci Poly. (One Meter Cs-137 Dose Rate, mR/hr/Ci) Poly. (One Meter Co-60 Dose Rate, mR/hr/Ci)**41** Waste Container Dose-to-Curie Conversion Record

**DTC Spreadsheet Version 1 102307**

**Date of Survey 8/22/2002** 
**Waste Stream Designation SR-RL-BCLDP.001**

**Container Number BC00AA** 
**Container Gross Weight 147.4 kg** 
**Estimate Fill Percentages 100 %** 
**Container Net Weight 46.7**

**Measured Container Dose Rate**

**Detector #1 100 mR/hr** 

**Detector #2 100 mR/hr** 
**Calculated Average Dose Rate 100 mR/hr**

Nuclide Curie

Scaling Factors Activity

(Ci) Grams FGE PECi Watts Uncertainty Uncertainty in Curies Uncertainty

in Grams

U-233 5.12E-05 **2.81E-05 2.88E-03 2.59E-03 7.21E-06 8.18E-07 164.41 % 4.62E-05 4.73E-03** 

U-234 2.59E-05 **1.42E-05 2.25E-03 0.00E+00 0.00E+00 4.09E-07 85.55% 1.22E-05 1.92E-03** 

U-235 3.58E-07 **1.96E-07 8.97E-02 5.77E-02 0.00E+00 5.42E-09 101.10 % 1.99E-07 9.07E-02** 

U-238 5.89E-06 **3.24E-06 9.52E+00 0.00E+00 0.00E+00 8.20E-08 65.33% 2.11E-06 6.22E+00** 

Pu-238 3.41E-02 **1.87E-02 1.08E-03 1.22E-04 1.70E-02 6.20E-04 76.34% 1.43E-02 8.26E-04** 

Pu-239 5.83E-03 **3.20E-03 5.09E-02 5.09E-02 3.20E-03 9.92E-05 64.30% 2.06E-03 3.27E-02** 

Pu-240 9.48E-03 **5.21E-03 2.27E-02 5.10E-04 5.21E-03 1.62E-04 62.80% 3.27E-03 1.42E-02** 

Pu-241 6.87E-01 **2.90E-01 2.79E-03 6.28E-03 5.69E-03 9.23E-06 79.63% 2.31E-01 2.22E-03** 

Pu-242 3.01E-05 **1.65E-05 4.16E-03 3.12E-05 1.50E-05 4.87E-07 88.12% 1.46E-05 3.67E-03** 

Am-241 5.00E-02 **3.04E-02 8.76E-03 1.64E-04 3.04E-02 1.02E-03 76.10% 2.31E-02 6.66E-03** 

Cm-244 1.76E-02 **7.85E-03 9.60E-05 8.64E-06 4.13E-03 2.70E-04 152.91 % 1.20E-02 1.47E-04** 

Cs-137 1.00E+00 **4.85E-01 5.51E-03 0.00E+00 0.00E+00 5.36E-04 54.30% 2.63E-01 2.99E-03**  Ba-137m 9.46E-01 **4.59E-01 8.53E-10 0.00E+00 0.00E+00 1.81E-03 54.30% 2.49E-01 4.63E-10**  Sr-90 6.77E-01 **3.26E-01 2.36E-03 0.00E+00 0.00E+00 3.78E-04 55.75% 1.82E-01 1.32E-03**  Y-90 6.77E-01 **3.26E-01 5.99E-07 0.00E+00 0.00E+00 1.80E-03 55.75% 1.82E-01 3.34E-07** 

Totals **1.95E+00 9.71E+00 1.18E-01 6.57E-02 6.70E-03**

**Value (one Sigma) TRU Alpha Activity Concentration 1.23E+03 6.55E**  **+02 nCi/g TRU Alpha Activity 5.75E-02 3.06E-02 Ci**  **Total Pu-239 Equiv Activity 6.57E-02 3.57E-02 Ci Total Pu-239 Fissile Gram Equiv 1.18E-01 7.39E-02**  **g Total Decay Heat 6.70E-03 3.62E-03 W**  **Volume Activity 1.72E-02 9.69E-03 Ci/L**

Figure 4. Example Waste Drum DTC Conversion Record**42**

**(5) The definition of this RH waste stream was asse ssed and found to be adequate.** 

**This inspection focused on a group of 87 drum liner s of RH wastes that SRS-CCP stated were**  **contained in a single waste stream, all of which we re generated from the D&D of the JN-1 HCL**  **under the BCLDP. The EPA inspection team concluded that the assignment of all 87 RH drum**  **liners to a single waste stream was technically sup portable.** 

**(6) Several technical aspects of the radiological characterization process were evaluated and**  **were found to be acceptable.**

**Fourteen calculation packages were prepared and rev iewed by Jene Vance, Jim Holderness, Rob**  **Tayloe and Larry Porter to document development of the scaling factors and the DTC correlation**  **discussed above. These packages provide the techni cal basis for several aspects, including:** 

• **Application and verification of Microshield ®**  **and ORIGEN2.2**

• **Evaluation of all potential contributors to a conta iner’s dose rate, specifically**  **137 Cs and** 
**60 Co, and addressing contribution of other fission pr**  **oducts**

• **Development and comparison of scaling factors for t hree fuel types: LWR, thorium uel,**  **and HEU**

• **The nature and history of the LWR fuels examined in the JN-1 facility** 

• **Decay correction of the BCLDP swipe data used to co nfirm the ORIGEN2.2 LWR**  **calculations**

• **Potential sources of uncertainty [see total measure ment uncertainty (TMU), below]** 

**The EPA inspection team members reviewed these 14 p ackages during the July 2007 inspection**  **and discussed them with the documents’ authors and other SRS-CCP personnel. During these**  **discussions, the EPA inspection team questioned sev eral aspects and identified instances where**  **modifications to the calculation packages were requ ired. Some of the modifications required a**  **formal revision of the calculation package (see “Do cuments Reviewed” in Section 8.0, above).**  **The EPA inspection team reviewed the revised docume nts at the December 2007 meeting and**  **also had the opportunity to discuss all technical c oncerns and discrepancies with SRS-CCP**  **personnel. The EPA inspection team found the revis ed calculation packages to adequately**  **document the technical activities upon which the ra dionuclide scaling factors were based. All**  **technical issues related to the documentation of te chnical aspects of the SRS-CCP RH WC**  **approach were resolved.**

**(7) Evaluation of TMU was performed and found to be adequate following revision of**  **specific SRS-CCP documents.**

**The development of TMU for the 87 drum liners in Wa ste Stream SR-RL-BCLDP.001 is based**  **on the propagation of uncertainties present in all aspects of the determination of the radiological**  **constituents of RH TRU waste. The TMU determinatio n included the contributions of:** **43**

• **Drum liner weight measurement**

• **137 Cs measurement uncertainty** 

• **Scaling factor uncertainty**

• **MicroShield ®**  **issues**

• **Other gamma emitters**

• **Individual fuel pin contribution to the total in wa ste liner** 

• **Burnup history**

• **Internal code issues**

• **Modeling**

**The treatment of TMU is presented in CCP-AK-SRS-501 , Revision 1, and Calculation Package**  **No. SRS-RH-06, Revision 0, “Uncertainty Analysis.” During the July 2007 inspection, the EPA**  **inspection team determined that these documents did not adequately present the technical basis**  **for the TMU related to the SRS-CCP BCLDP wastes, as discussed below. Additionally,**  **operational aspects of the TMU process were not ade quately documented. This issue was**  **discussed with SRS-CCP personnel during the July 20 07 inspection and was included as one**  **aspect of Issue (d) in EPA Finding No.SRS-RH-AK-07-0 01F (see Attachment A of this report**  **for a copy of this form). The other aspect of Issu e (d) is addressed in Section (7), below.** 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d): **The technical basis for the characterization of these RH wastes with respect to the documentatio**  **n of Total Measurement Uncertainty (TMU) was not adequately documented in CCP-AK-SRS-501, Re**  **vision 1 and Calculation Package No. SRS-RH-06, Revision 0.** 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolu tion: **Following the July 2007 inspection, SRS-CCP produced Revision 2 of CCP-AK-S**  **RS-501, and Revision 1 of SRS-RH 06, both of which were reviewed by the EPA inspecti**  **on team member assessing radiological characterization during the December 2007 meeting.**  **Both documents had been modified to better present the technical basis for the TMU dete**  **rmination and to appropriately document the process. They included contributions of all pertin**  **ent aspects of the TMU, which are summarized in CCP-AK-SRS-501, Table 8-3, and reproduced as Tab**  **le 6, below. Upon reviewing the revised documents the EPA inspection team determined that t**  **he treatment of TMU for the BCLDP RH wastes was technically adequate and appropriately d**  **ocumented and that the aspect of this issue related to TMU was addressed.** 

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status : **This issue is closed. 44** 

Table 6. Overall Uncertainty Listed by Radionuclid e at a Density of 1.0 g/cm 3

Radionuclide Dose Rate

Measurement Uncertainty Other

Gamma Emitters Microshield ®

Code Uncertainty Microshield ®

Model Uncertainty Scaling

Factor Uncertainty Total

Uncertainty

**233 U 25.0% 45.6% 10.0% 31.4% 155.2% 167.0%** 

**234 U 25.0% 45.6% 10.0% 31.4% 66.1% 90.4%** 

**235 U 25.0% 45.6% 10.0% 31.4% 85.3% 105.2%** 

**238 U 25.0% 45.6% 10.0% 31.4% 36.3% 71.5%** 

**238 Pu 25.0% 45.6% 10.0% 31.4% 53.7% 81.7%** 

**239 Pu 25.0% 45.6% 10.0% 31.4% 34.4% 70.6%** 

**240 Pu 25.0% 45.6% 10.0% 31.4% 31.6% 69.2%** 

**241 Pu 25.0% 45.6% 10.0% 31.4% 58.2% 84.8%** 

**242 Pu 25.0% 45.6% 10.0% 31.4% 69.4% 92.8%** 

**241 Am 25.0% 45.6% 10.0% 31.4% 53.3% 81.5%** 

**244 Cm 25.0% 45.6% 10.0% 31.4% 143.0% 155.7%** 

**90 Sr 25.0% 45.6% 10.0% 31.4% 12.6% 62.9%** 

**137 Cs 25.0% 45.6% 10.0% 31.4% N/A 61.6%** 

**(8) Radionuclide Documentation in lieu of BDRs was assessed and found to be adequate**  **upon revision of specific SRS-CCP documents.**

**The 87 drum liners of SRS-CCP RH TRU waste were not documented in BDRs, as is typically**  **done at TRU waste sites. Instead, the formal docum entation for each canister’s radionuclide**  **values was presented in CCP-AK-SRS-501, Revision 1, Attachment 3, pages 47 through 134.**  **The EPA inspection team verified that the data shee t for each RH TRU liner contained the**  **following information:**

• **Container number**

• **Waste stream designation**

• **Net waste weight**

• **Waste material type**

• **Measured dose rates from two detectors and the calc ulated average dose rate in mR/hr** 

• **Scaling factor in grams or curies per mR/hr**

• **Activity values and uncertainties for the 10 WIPP-t racked radionuclides in nCi/g** 

• **TRU alpha activity and concentration**

• **Plutonium equivalent curies (PE Ci) in curies**

• **Fissile gram equivalents (FGE) in grams 45** 

• **Decay heat in watts**

• **Volume activity in curies per liter**

**There were several aspects of CCP-AK-SRS-501, Revis ion 1, that required clarification, and**  **these prevented a complete technical evaluation of the radiological characterization of the 87 RH**  **TRU drum liners during the Denver inspection. Thes e aspects were discussed with SRS-CCP**  **personnel during the inspection, and were included as the second aspect of Issue (d) in EPA**  **Finding No. SRS-RH-AK-07-001F, part of which is disc ussed in Section (6), above (see**  **Attachment A of this report for a copy of this form ). The other aspects of this finding related to**  **radiological characterization are discussed below.**

EPA Finding No. SRS-RH-AK-07-001F, Issue (d): **The general issue was that CCP--AK-SRS-501 did not adequately document the tec**  **hnical basis for the characterization of these RH wastes with respect to the development of**  **radionuclide scaling factors. The specific issues are as follows:** 

• **CCP-AK-SRS-501 provides the technical basis of the derivation of the radionuclides**  **values for each of the 87 RH TRU drum liners. This document is based on statistical**  **treatments of various data sets that are presented in the calculation packages listed in**  **Section 8.0 above. However, the statistical approa ches incorporate both simple**  **arithmetical means and standard deviations, as well as geometric mean and standard**  **deviations, and the documentation of which statisti c is used is often unclear. It appears**  **the incorrect statistic is used in some cases, but the calculation packages are not**  **sufficiently clear to allow their technical evaluat ion.** 

• **CCP-AK-SRS-501 contains several areas that require rewriting to accurately document**  **the technical basis of a specific aspect of the rad iological characterization process.**  **Examples include: clarification that the uncertaint y for**  **233 U is based on the standard**  **deviation of the 234**  **U; treatment of the LLD; inclusion of references fo r specific activity,**  **decay heat, etc.; and addressing where in the proce ss the TRU determination is**  **performed.**

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Resolu tion: **CCP-AK-SRS-501 and other calculation packages were revised appropriately and**  **were provided to EPA at a December 2007 meeting (see “Documents Reviewed” in Section 8.0, a**  **bove). The statistical inconsistencies in CCP-AK-SRS-501 and the accompanying calculation pac**  **kages were corrected, as documented in the revised documents the EPA inspection team re**  **viewed. Clarification regarding the 233**  **U uncertainty, additional details regarding the LLD,**  **and the appropriate references for specific activity, decay heat and other derived quantities w**  **ere included (CH-TRAMPAC) in the revised documents made available to EPA at the December 200**  **7 meeting in Carlsbad, New Mexico. The treatment of TMU presented in Revision 2 of CCP**  **-AK-SRS-501 provides details that were missing from Revision 1 that was evaluated at the J**  **uly 2007 meeting in Denver. Revision 2 of CCP-AK-SRS-501 and the revisions of the accompanyin**  **g calculation packages discussed earlier contained sufficient technical details to adequatel**  **y address the EPA concern.**

EPA Finding No. SRS-RH-AK-07-001F, Issue (d) Status : **This issue is closed. 46** 

**(9) RH and TRU determinations were evaluated and fo und to be adequate.** 

**The records addressing the determination that the 8 7 RH TRU drum liners met the definition of**  **TRU wastes (TRU alpha activity concentration greate r than 100 nCi/g) and RH waste (contact**  **dose equivalent rate in excess of 200 mrem/hr) were examined, as discussed below.** 

• **TRU definition: As stated previously, BDRs were not prepared for the 87 RH TRU drum**  **liners in this waste stream. The radionuclide valu es that were determined for the liners**  **are contained in CCP-AK-SRS-501, Attachment 3, page s 47 through 134. All liners**  **indicate TRU concentrations greater than 100 nCi/gr am.** 

• **RH definition: The external exposure rate (dose rat e) measurements of each of the RH**  **TRU liners were made at the time the liners were fi lled, and the measured values are**  **recorded on Health Physics Survey Reports Form DDO- 138 in mR/hr. All measurements**  **were made at a distance of 1 meter at the midpoint of the liner’s height in two locations**  **180o degrees apart, i.e., at the three o’clock and nine o’clock positions, and the value**  **recorded for each liner was the arithmetical averag e of both measurements. The**  **documentation examined during the inspection shows that radiation surveys were**  **controlled by a formal, written procedure, HP-OP-01 9, “Radiation and Contamination**  **Survey Techniques”; survey procedures cite the appr opriate consensus standard,**  **ANSI/NCSL Z540-1; all dose rate measurements were mad e with the appropriate type of**  **instrument; the serial number for each instrument w as listed; all instruments had a current**  **calibration at the time of measurement; and all sur veys were performed under a radiation**  **work permit that was identified. The measurement r ecords for the liners indicate external**  **dose rates greater than 200 mR/hr in all cases.**

**There were no concerns regarding the TRU and RH det erminations for Waste Stream**  **SR-RL-BCLDP.001.**

8.3 Physical Form and Prohibited Item Characterization – Visual Examination

**From July 31 through August 1, 2007, EPA performed an inspection of SRS-CCP’s VE activities**  **for RH TRU waste from the BCLDP in storage at SRS. SRS-CCP possesses both written and**  **audio/video records of packaging of 87 drum liners from Waste Stream SR-RL-BCLDP.001.**  **During this inspection EPA’s focus was on independe nt verification of the acceptability of VE**  **data contained within the historic records. The re view took place at the CBFO offices located in**  **the Skeen Whitlock Building in Carlsbad, New Mexico**

**. The VE data reviewed were generated between late 19**  **99 and late 2002, in accordance with procedure TC-OP-01.4 and work instructions WI-956 a**  **nd 958. The procedure had been revised during this time period and SRS-CCP had retrieved R**  **evisions 1 and 2 but did not possess Revision 0. Training of VE personnel was performed**  **in accordance with TCP-98-05 and TRU-100.** **47**

**(1) Training of VE personnel was assessed and found to be adequate.** 

**All of the personnel who performed VE were contract employees, and all had been trained to**  **applicable site procedures. How these employees we re used is documented in the interface**  **document TCP-98-04. The practice at the time the R H drum liners were packaged was to**  **destroy old training records as new ones were gener ated. Consequently, SRS-CCP could not**  **obtain complete training records for all VE personn el that were involved in the BCLDP project.**  **However, EPA was able to review some training recor ds from the packaging time period,**  **approximately 1999 to 2002.**

**Procedure TC-OP-01.4 refers to a Visual Examination Expert (VEE) performing the**  **examinations. From the activities performed, EPA c oncluded that at the time of packaging**  **Waste Certification Officials (WCOs) were equivalen t to present day VEEs and VEEs were**  **equivalent to present day VE operators. VE operato rs and VEEs were required to read**  **procedures and be re-qualified every three years.**

**(2) Audio/video and written records were reviewed a nd found to be adequate.** 

**The EPA inspection team selected a random sample of four RH drum liners containers to review**  **during this inspection, Nos. BC0035, BC0051, BC0070 , and BC012. Because drum liners were**  **filled over extended periods of time, the recording s for many containers were recorded on**  **multiple tapes. For example, the VE of container No . BC0035 is recorded on tapes E00025,**  **E00034, E00035, E00036, E0038, E00038, E00039, and E00040. Two types of recordings were**  **made, one from a movable focus/angle camera and one from a fixed camera. Although the**  **movable camera images are required to review the VE event, the fixed camera image shows a**  **much wider field of view and provides a superior ov erview of the process. For the purpose of**  **this inspection, EPA reviewed the movable camera au dio/visual tapes for selected packages.**  **They were evaluated as follows:**

• **BC0035, packages 15, 29, 59, and 66: The EPA inspe ction team did briefly review the**  **static video for this drum liner but it was not pos sible to verify the waste items placed in**  **the receiving container using this recording. Howe ver, using the movable camera**  **recording the EPA inspection team verified that the waste items individually placed into**  **the receiving container were correctly identified a nd recorded. The waste items in this**  **drum liner included plastic, rubber, cloth, and pap er. The original packaging took place**  **in November 2000 and was reviewed in October 2002. The revision date for the TRU**  **Waste Packaging Loading Record, Loading – Itemized Data record was February 1999.** 

• **BC0051, packages 7 and 17: The majority of waste i n this drum liner was steel and other**  **metals. The original packaging took place during J uly and August 2000 and review of**  **the paper and visual records was performed in Febru ary 2003. The EPA inspection team**  **did not identify any discrepancies between the writ ten and visual/audio records. The**  **revision date for the TRU Waste Packaging Loading R ecord, Loading – Itemized Data**  **record was February 1999.**

• **BC0070, packages 11 and 14: The revision date for the TRU Waste Packaging Loading**  **Record, Loading – Itemized Data record was August 2 001. This revision of the sheet** **48**

**required additional information to be recorded, inc luding the number of the liner filter,**  **drum filter number and seal, and WMC. This drum li ner arrived in the processing area**  **already full of waste. The waste was tipped onto t he sorting tray, identified, and then**  **loaded. Similar waste items were loaded into opaqu e, white buckets, which were then**  **emptied into the receiving container. Placing of i tems in the white buckets was not**  **recorded, but the items from each bucket were calle d out (identified orally), as it was**  **loaded. This was discussed with SRS-CCP and the EP A inspection team agreed that this**  **method of drum liner loading did not compromise the technical adequacy of the VE data.**  **Packaging took place in June 2002 and the records w ere reviewed in November 2002.** 

• **BC0120, packages 4 and 7: This bucket was empty wh en first viewed on the audio/visual**  **recording. The VE process for this container was s imilar to the process used for BC0070,**  **because the placing of items in white buckets was n ot recorded. Waste items were**  **identified as they were tipped into the receiving c ontainer. Packaging took place in**  **December 2001, and the records were reviewed in Jan uary 2002 and November 2002.** 

**The absence of prohibited items was verified during packaging and review of records and no**  **discrepancies between the written and visual/audio records for these drum liners were identified.**  **The EPA inspection team determined that WMPs were c orrectly identified and the physical form**  **of the waste was verified. There are no issues rel ated to the use of VE for SRS-CCP RH TRU**  **wastes as a result of this inspection.**

8.4 WIPP Waste Information System

**From July 31 through August 1, 2007 EPA reviewed SR S-CCP’s WWIS activities for RH TRU**  **waste in Carlsbad, New Mexico because access to the WWIS database and CCP personnel**  **responsible for maintaining the database were readi ly available at that location.** 

**EPA previously approved this process and the purpos e of this review was to ensure continued**  **compliance with the requirements of the WCPIP. At the time of the review, a total of 132 RH**  **waste containers from INL and ANLE had been emplace d in the WIPP repository, and an**  **additional 68 RH waste containers had been approved for shipment. The EPA inspection team**  **interviewed a CCP WCO and investigated the CCP WWIS procedure by reviewing data for**  **Canister No. ID0051. The canister housed three cont ainers of RH waste, Container Nos.**  **001131, 001141, and 001143, from RH Waste Stream ID -ANLE-S5000. The same CCP WWIS**  **procedure is used for RH wastes from all DOE sites.**

**Since EPA approval, CCP has successfully submitted characterization and certification data into**  **WWIS for RH waste from INL and ANL. EPA had conduc ted a baseline inspection at both sites**  **and approved them for RH WC activities previously. The DTC, VE, or RTR data sheets are used**  **to populate a WWIS Data Entry Summary spreadsheet. The WCO interviewed was able to**  **retrieve the spreadsheet and characterization data sheets for container No. 001131. The EPA**  **inspection team verified that the spreadsheet infor mation matched that in the WIPP Waste**  **Container Report for this container. No discrepanci es were identified. The WIPP Waste**  **Container Report for Canister No. ID0051 was also re trieved and reviewed. Using the WIPP**  **Waste Container Reports for the internal containers , the EPA inspection team verified that there**  **were no data errors or discrepancies between these reports.** **49**

**The EPA inspection team verified that all WMPs for each RH container were reported to WWIS**  **as plastic. EPA calculated the material parameter weights provided in the Waste Container Data**  **Report for each of the inner containers of Canister No. ID0051 and ensured that value was the**  **same as the reported container gross weight. No dis crepancies were found for the three**  **containers the EPA inspection team reviewed.**

**Prior to submitting container data to the WWIS for certification, the NCR and Corrective Action**  **Report (CAR) status of each container was verified. Container data were uploaded to WWIS**  **after this check, based on information that was obt ained from CCP QA personnel. EPA verified**  **this process by reviewing an email verifying the NC R/CAR status for containers in INL RH**  **Lot 9. If data were rejected by WWIS, actions were taken to correct and resubmit the data. EPA**  **verified this process by reviewing the history for Container No. 001117 that was rejected by**  **WWIS on June 7, 2007. CCP resolved the data issue and successfully resubmitted the container**  **to WWIS on July18, 2007. As required by the WCPIP, all WMPs are reported to WWIS as**  **plastic. CCP continues to successfully submit RH T RU data for both characterization and**  **certification to WWIS. There were no issues relati ve to CCP’s implementation of the WWIS for**  **RH TRU wastes identified during this audit.**

8.5 Attainment of Data Quality Objectives

**(1) Verification methods for each DQO were assessed and found to be compliant with the**  **WCPIP.**

**SRS-CCP-BCLDP representatives indicated that AK is the basis for all characterization, and AK**  **will be qualified entirely through demonstration of an equivalent QA program. As indicated**  **previously, this approach comports with requirement s set forth in the WCPIP.** 

**(2) Attainment of DQOs was evaluated and found be a dequate.** 

**As a result of the analyses presented in Sections 8 .1 through 8.4, above, the EPA inspection team**  **assessed how each DQO was addressed. As required i n the WCPIP, the following DQOs must**  **be addressed:**

• **Defense determination**

• **TRU waste determination**

• **RH waste determination**

• **Activity determination (TRU alpha activity per drum liner, including identification and**  **quantification of 10 WIPP-tracked radionuclides)**

• **Residual liquids**

• **Physical form, including metals and cellulosics, pl astic and rubber** 

**All DQOs are based on AK that is verified through d emonstration of an equivalent QA program,**  **and EPA has assessed each element for its technical merit based on the AK record. EPA**  **concludes that SRS-CCP-BCLDP has adequately present ed how DQOs will be obtained.** **50**

9.0 RESPONSE TO COMMENTS

**On May 21, 2008, EPA issued an FR notice (73 FR 295 04-29507) proposing approval of the RH**  **TRU debris waste from BCLDP and WC processes SRS-CC P used when characterizing this**  **waste. EPA received one comment that was sent to D ocket ID No. EPA-HQ-OAR-2008-0410.**  **The actual comment was an enclosure to a July 3, 20 08 letter and is included below verbatim,**  **followed by EPA’s response to the comment.**

Comment:

**Comments concerning the United States Environmental Protection Agency (EPA)**  Proposed Approval of the Central Characterization P roject’s Remote-Handled Waste Characterization Program at the Savannah River Site **published in the Federal Register on Wednesday May 21, 2008, Volume 73, No. 99, starti**  **ng on page 29504.**

**Within the Federal Register Notice, EPA states that, “Upon approval of the RH TRU**  **waste characterization processes discussed in this report, if SRS-CCP embarks on**  **characterizing RH waste other than that generated a t BCLDP for WIPP disposal, a**  **separate baseline inspection and approval will be n ecessary. That is, any SRS RH waste**  **destined for WIPP disposal characterized by SRS-CCP or another program remains**  **subject to EPA’s baseline inspection and approval” (page 29506, third column).** 

**The Carlsbad Field Office (CBFO) disagrees with the assertion that a new baseline would**  **be necessary if additional RH waste were characteri zed at SRS by CCP.** 

**The Code of Federal Regulations, 40 CFR, Part 194, Section 194.8, subsection b(2)**  **states, “The Agency (EPA) will** verify **the compliance of waste characterization**
programs **and** processes **. . .” [emphasis added]. By publishing the propose d approval of**  **the SRS-CCP Remote-Handled Waste Characterization P rogram in the Federal Register,**  **EPA has memoralized its determined [** sic **] that the following CCP processes in place at SRS are compliant with 40 CFR, Part 194, Section 19**  **4.8, subsection b(1).**

**(1) The acceptable knowledge process (page 29506, third**  **column) (2)**  **The radiological characterization process using dos e-to-curie (page 29507,**  **first column) (3)**  **The visual examination process (page 29507, first c olumn)**  **(4) The WIPP Waste Information System (page 28507, firs**  **t column) (5)**  **The attainment of pertinent Data Quality Objectives (page 29507, first**  **column)**

**Therefore, The Department of Energy (DOE) contends that the adequacy of these**  **processes has been successfully implemented in acco rdance with 40 CFR, Part 194,**  **Section 194.8, subsection b(1) as demonstrated by C CP at SRS during the baseline**  **inspection and as indicated in the pending approval . A requirement to re-demonstrate the**  **same processes, should they be used at SRS, would n ot be a judicious use of either EPA’s** **51**

**or DOE’s resources and would not be good stewardshi p of the finite resources available**  **for the TRU program.**

EPA Response to Comment:

EPA agrees with the commenter that CCP had successf ully implemented the above listed waste characterization processes demonstrated to EP A during the baseline inspection. EPA, however, disagrees that a re-demonstration of implemented waste characterization processes is not necessary and is not a judicious u se of resources for the TRU program available to DOE and EPA.

To date, EPA has inspected and evaluated CCP’s RH WC program for debris waste from Idaho National Laboratory (INL), Argonne National L aboratory (ANL), Los Alamos National Laboratory (LANL), Battelle Columbus Labor atory (BCL), and Oak Ridge National Laboratory (ORNL). The experience from th ese five inspections indicates that CCP has customized their radiological characterizat ion and acceptable knowledge WC processes to address unique aspects of RH debris was te at each generator site.

The radiological characterization processes observe d at these five CCP RH sites have varied. For example, INL and ANL used real-time me asured external dose-rate (gamma) and DTC on large populations of containers with ORIG EN-based scaling factors expressed in curies of TRU radionuclides per curie of 137 Cs based on fuel characteristics and burn up. At LANL, the 137 Cs content for each container was calculated in mas s and the 137 Cs activity was then derived using a curie-to-dose scaling factor based on historical passive-active neutron measurements from the 1980s for a small, discreet set of wastes. At SRS (BCL), radiological characterizatio n is based on historical dose-rate measurements and the agreement between scaling fact ors derived from LWR fuel data and the radiochemical results of the 69 swipe sampl es discussed in Section 8.2 of this report. At ORNL, ORIGEN was not used and scaling f actors were instead based on radiochemical and non-destructive analyses of sampl es that contained predominantly exotic transcurium radionuclides and negligible amo unts of plutonium. While there are broad similarities among these five RH WC programs, the differences in the specific techniques are pronounced and the radiological char acterization approaches have been largely site-specific. The only RH WC aspects that were common among these sites are non-destructive examination to confirm the absence of prohibited items (free liquid and aerosol cans) and tracking of waste container conte nts in the WWIS.

Given these substantial differences in WC procedure s, EPA concludes there is no basis for EPA to determine that SRS-CCP could effectively implement the WC processes used for the BCL debris waste to characterize other RH w aste. Therefore, the proposed approval stated that a new baseline would be necess ary if SRS-CCP were to apply the processes described in EPA’s inspection report to c haracterize other non-BCLDP RH waste. EPA maintains that position in this final a pproval. Also, as stated previously, implementation of the RH WC processes described in this report for characterizing nondebris BCLDP waste and/or BCLDP wastes other than t he 87 RH drum liners is a T1 change.**52**

10.0 CONCLUSIONS

**EPA’s inspection team determined that SRS-CCP’s RH WC program activities were technically**  **adequate. EPA is approving the SRS-CCP-RH WC progr am as supported by the documentation**  **examined during this inspection and described in th is report. The approval includes the AK**  **process for one RH retrievably stored TRU debris wa ste stream, SR-RL-BCLDP.001, that was**  **generated by the BCLDP consisting of 87 drum liners that are currently stored at SRS. All**  **aspects of the SRS-CCP documentation in support of this RH waste stream are technically**  **adequate.**

**EPA requires that all site-specific CCRs at RH TRU sites must address the 10 WIPP-tracked**  **radionuclides, as discussed in Section 8.1 (8) of t his report** 

**. SRS-CCP must provide to EPA a**  **copy of the WWIS controlled spreadsheet showing the manual data entries that were downloaded**  **from CCP-AK-SRS-501 upon completion. In the future, when sample collection plays as**  **important a role in a site’s RH WC program as it do es for this BCLDP waste stream, EPA will**  **require that the site provide a sampling plan prior to EPA approval.** 

Baseline Approval

**The documents that EPA reviewed during the inspecti on that are listed in Section 8 of this report**  **adequately support the characterization of SRS-CCP RH Waste Stream SR-RL-BCLDP.001.**  **The waste stream being approved by EPA is of a fini te nature (i.e., 87 TRU RH drum liners) that**  **was generated and packaged in the past, and no addi tional waste containers from BCL belonging**  **to this waste stream exist at SRS or would be subje cted in the future to the WC techniques**  **described in the report. Hence, this baseline appr oval remains applicable only to the debris**  **waste from BCL consisting of 87 TRU RH drum liners and cannot be implemented to**  **characterize any additional waste containers from t his waste stream. As stated in Section 9.0,**  **should SRS-CCP request approval of any non-BCL RH w aste generated at SRS or waste brought**  **to SRS for characterization, a new baseline inspect ion will be necessary.** 

**The wastes to which this approval applies are discu ssed in this report and were generated at the**  **BCLDP; the fact that they are stored at SRS has no bearing on characterization activities**  **performed on any other CH or RH TRU materials at SR S or any other DOE site. This report**  **does not list any specific T1 or T2 designations re lative to these 87 waste liners and the WC**  **components inspected and approved by EPA at this ti me. However, should DOE identify**  **additional containers of RH TRU wastes (e.g., solid s or soil/gravel) associated with the D&D of**  **the Building JN-1 HCL at the Jefferson North Facilit y as being eligible for WIPP disposal apart**  **from the 87 liners that are discussed in this repor t, EPA notification and approval would be**  **necessary as a T1 change. This report does not lis t specific T1 or Tier 2 (T2) designations**  **relative to these 87 drum liners containing RH TRU debris waste from BCLDP and the WC**  **components approved at this time. SRS-CCP, however , must provide to EPA a copy of the**  **WWIS controlled spreadsheet showing the manual data entries that were downloaded from CCP**  **AK-SRS-501 upon completion as a one-time T2 change. 53** 

11.0 REFERENCES

**U.S. Department of Energy, Carlsbad Area Field Offi ce, “Contact-Handled Transuranic Waste**  **Acceptance Criteria for the Waste Isolation Pilot P lant (CH-WAC),” Revision 3, DOE/WIPP-02-**  **3122, Carlsbad, New Mexico, April 25, 2005.**

**U.S. Environmental Protection Agency, “Criteria for the Certification and Recertification of the**  **Waste Isolation Pilot Plant’s Compliance with the D isposal Regulations: Certification Decision;**  **Final Rule,”** Federal Register **, Vol. 63, No. 95, May 18, 1998, pp. 27354, 27405.**

**U.S. Code of Federal Regulations,** Title 40

**,** Protection of Environment **, Part 191, “Environmental Radiation Protection Standards for Management and D**  **isposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes.”** 

**U.S. Code of Federal Regulations,** Title 40

**,** Protection of Environment **, Part 194, “Criteria for the Certification and Re-Certification of the Waste Iso**  **lation Pilot Plant’s Compliance with the 40 CFR Part 191 Disposal Regulations.”** 

**U.S. Department of Energy, Carlsbad Area Field Offi ce, “Remote Handled TRU Waste**  **Characterization Program Implementation Plan”, DOE/ WIPP-02-3214, Revision 0D, Carlsbad,**  **New Mexico, October 30, 2003.**

**U.S. Department of Energy, Title 40 CFR Part 191, C ompliance Certification Application for the**  **Waste Isolation Pilot Plant, DOE/CAO 1996-2184, Car lsbad, New Mexico, 1996.** 

**U.S. Department of Energy, Title 40 CFR Part 191, S UBPART D AND C, Compliance**  **Recertification Application 2004, DOE/WIPP/2004-323 1.** 

**U.S. Department of Energy, Carlsbad Area Field Offi ce, “Quality Assurance Program**  **Description (QAPD)”, DOE/CBFO-94-1012, Revision 7, Carlsbad, New Mexico, July 2005.** 

**U.S. Nuclear Regulatory Commission, “Contact-Handle d Transuranic Waste Authorized**  **Methods for Payload Control (CH-TRAMPAC).”**Attachment A

EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-RH-AK-07-001F**A-1** Attachment A EPA Inspection Issue Tracking Form, EPA Issue No. SRS-CCP-RH-AK-07-001F
Inspection No. **EPA-SRS-CCP-RH-07.07-8** Issue Number: **SRS-RH-AK-07-001F** , **Revision 3** Date: **July 19, 2007** Inspectors: **C. Walker/P. Kelly** Attachments? **YES NO**  Sample Size: **RH Documentation** Population size (if known): **NA** Description of Issue: **In August 2001, EPA conducted a surveillance of t he Battelle Columbus (BC) Remote-Handled**  **(RH) Waste Characterization Program. In the report sent to DOE (cited below), EPA stated that: “BC’s**  **RH Program could be improved through more diligent acquisition and i**  **ntegration of AK-based radionuclide information to determine isotopic**  **distributions.” EPA also questioned the representa tiveness of swipe samples collected that were later**  **used as part of scaling factor/JN-1 isotopic mix development. EPA conclude**  **d that the “AK program data assembly/compilation el ements were not**  **complete” (EPA’s Technical and Regulatory Support D ocument for RH Waste Determination, February 2004,**  **transmitted to DOE by Frank Marcinowski, March 26, 2004). EPA**  **also concluded that while the radioassay approach h ad merit,**  **characterization activities performed to support th e approach at the time of the 2001 Surveillance “we**  **re not technically adequate.” EPA’s current inspection identifies the**  **following issues related to the completeness and a dequacy of AK and**  **radiological characterization documents, many of wh ich are related to issues identified in our August**  **2001 surveillance:**

**a. Isotopic ratio/composition information from two primary sources was used to develop scaling factor**  **s (also the JN-1 Standard Isotopic Mix). The factors were derived f**  **rom a combination of swipe sample and modeling resu lts, with input**  **data to the model (ORIGEN2.2) covered in a memorand um of a meeting in 1999. In order for this to serv**  **e as an auditable record additional information and rationale support**  **ing the approach are required for both the isotopic swipe data and the**  **recommended burn up, enrichment, and decay data con tained in the 1999 meeting memorandum. Documentat**  **ion of the references and data sources reviewed and evaluated**  **during the 1999 meeting is necessary to support con clusions. With**  **regard to the swipe data, the sampling plan, collec tion, number, results and other relevant informatio**  **n must be summarized to show that the sample data are sufficiently repre**  **sentative of the wastes within waste stream SR-RL-B CLDP.001.** 

**b. CCP-AK-SRS-500 must be revised to address the f ollowing:** 

• **Only describe the SRS waste stream of 87 liners sub ject to this inspection.** 

• **The document states that there are wastes in this s tream that exhibit both “standard” and “non-standar**  **d” isotopic distributions and that non-standard waste will unde**  **rgo separate sampling and analysis. However, the A KE**  **indicated that only “standard” isotopic mix wastes are included in the stream, and there are no wastes**  **that underwent the alternative sampling and analysis app**  **roach discussed in the text.**

• **Include a thorough presentation of general radiolog ical characteristics of wastes. Information such a**  **s types of radionuclides handled in JN-1 in the various cells/**  **areas, origin of radionuclides (e.g., LWR), outlier s, and other**  **information necessary to provide a general overview of the radionuclides handled through the course of**  **JN-1 operations are necessary.**  **c. Through the course of the AK information acquis ition and interpretation process, the number of was**  **te streams identified in JN-1 has changed over time. Specifically, the c**  **urrent SR-RL-BCLDO.001 stream was originally identi fied as four**  **separate waste streams. There is no information gi ven to show these waste streams were combined into**  **a single stream. d. CCP-AK-SRS-501 does not adequately document the**  **technical basis for the characterization of these RH wastes with**  **respect to the development of radionuclide scaling factors and Total Measurement Uncertainty.**  B. Regulatory Reference: **40 CFR 194.24(c)** C. Site requirement(s): D. Discussed with: **J.R. Stroble, Eric D’Amico, Larry Porter, K. Peters , S. Schafer, R. Tayloe, M. Doherty** 
E. Additional Comments: **Item c above is resolved as a result of the prepara tion of reference C509. As a result of**  **changes made to primary documents to resolve items b and d above, there may be a need to make changes**  **to other primary or secondary documents. EPA expects to receive rev**  **ised copies of these documents with the response to this finding.**  F. Site Response Information: Site Response Required? **YES NO**  Site Response Due Date: **August 13, 2007**